Transcript Outline SPCC Guidance Doc

Overview:
The Spill Prevention, Control, and
Countermeasure (SPCC)
Guidance for Regional Inspectors
U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response
Office of Emergency Management
SPCC Guidance Document
 Is intended to assist regional inspectors in
reviewing a facility’s implementation of the
SPCC rule
 Establishes a consistent understanding
among regional EPA inspectors on how
particular provisions of the rule may be
applied
 Available as a guide to owners and operators
of facilities and the general public
 This slideshow presents an overview of the
topics covered in the Guidance Document.
 The full document is available at
www.epa.gov/oilspill
Overview: SPCC Guidance for Regional Inspectors
Disclaimer
 The statutory provisions and EPA regulations
described in this guidance document contain legally
binding requirements. The guidance document does
not substitute for statutory provisions or regulations,
nor is it a regulation itself.
 While the guidance document indicates EPA's
strongly preferred approach to assure effective
implementation of legal requirements, EPA
decisionmakers retain the discretion to adopt
approaches on a case-by-case basis that differ from
this guidance where appropriate.
 EPA welcomes public comments on the document at
any time and will consider those comments in any
future revision of the guidance document.
Overview: SPCC Guidance for Regional Inspectors
Guidance Document Contents
 Chapter 1: Introduction
 Chapter 2: Applicability of the SPCC Rule
 Chapter 3: Environment Equivalence
 Chapter 4: Secondary Containment and
Impracticability Determinations
 Chapter 5: Oil/Water Separators
 Chapter 6: Facility Diagrams
 Chapter 7: Inspection, Evaluation, and Testing
 Appendices
Overview: SPCC Guidance for Regional Inspectors
Chapter 1: Introduction
 SPCC Background
– Purpose and scope
– Statutory framework
 Regulatory History
– Initial promulgation
– Proposed revisions
 Overview of 2002 Revised Rule Provisions
 Using the Guidance Document
Overview: SPCC Guidance for Regional Inspectors
Using the Guidance Document
 Clarifies the role of the inspector in
reviewing implementation of performancebased provisions
 Is a “living document” and may be
updated or revised
 Does not address all aspects of the SPCC
rule
Overview: SPCC Guidance for Regional Inspectors
Chapter 2: Applicability
 Applicability criteria:
– Definition of “oil” and activities involving oil
– Definition of “facility”
– “Non-transportation-related” facilities –
EPA/DOT jurisdiction
– Definition of “discharge”
– Reasonable expectation of discharge to
navigable waters in quantities that may be
harmful
– Regulated storage capacity
– Various exemptions
Overview: SPCC Guidance for Regional Inspectors
Applicability, continued
 Regional Administrator
– Process for an RA to apply the SPCC rule to an
otherwise exempted facility
– Appeals process
 Different types of containers
– Bulk storage containers and oil-filled
equipment
 Applicability of facility response plan
requirements
Overview: SPCC Guidance for Regional Inspectors
Summary of SPCC Applicability
Chapter 3: Environmental
Equivalence
 The “environmental equivalence” provision
allows facilities to implement alternate measures
based on site-specific considerations
– Measures must provide equivalent environmental
protection, in accordance with good engineering
practice and as determined by a Professional
Engineer.
 Lists the substantive requirements eligible for the
provision, clarifies certain policy areas, and
provides examples
 Describes the role of EPA inspector in reviewing
deviations based on environmental equivalence
Overview: SPCC Guidance for Regional Inspectors
Environmental Equivalence,
continued
 Additional guidance on environmentally
equivalent measures for specific
requirements:
– Security
– Facility drainage
– Corrosion protection and leak testing of
completely buried metallic storage tanks
– Overfill prevention
– Piping
– Evaluation, inspection, and testing
Overview: SPCC Guidance for Regional Inspectors
Chapter 4: Secondary Containment
and Impracticability Determinations
 Overview of secondary containment provisions
– Example methods of containment
 General vs. specific provisions
 Sufficient freeboard
– Sample calculations of containment sizing
 Passive vs. active measures
– Examples of when each approach may be appropriate
 “Sufficiently impervious”
 Facility drainage requirements
Overview: SPCC Guidance for Regional Inspectors
Categories of Secondary
Containment Requirements
 General Provision, §112.7(c)
– Addresses the potential for oil discharges from all
regulated parts of a facility
– Containment method, design, and capacity are
determined by good engineering practice to
contain an oil discharge until clean-up occurs.
 Specific Provisions
– Address the potential of oil discharges from
specific parts of a facility where oil is stored or
handled.
– Containment design, sizing, and freeboard
requirements are specified by the SPCC rule to
address a major container failure.
Overview: SPCC Guidance for Regional Inspectors
Impracticability Determinations
 Additional requirements that accompany an
impracticability determination
 Documentation needed
 Detail on impracticability determinations for
certain areas:
– Piping and flowlines
– Transfer areas
– Oil-filled Equipment
– Loading/unloading racks
– Onshore bulk storage containers
– Mobile/portable containers
– Bulk storage containers at production facilities
– Onshore drilling and workover equipment
Overview: SPCC Guidance for Regional Inspectors
Chapter 5: Oil/Water Separators
 Provides applicable SPCC requirements
for oil/water separators used for:
– Wastewater treatment
– Secondary containment
– Oil production
Overview: SPCC Guidance for Regional Inspectors
SPCC Requirements for Oil/Water
Separator Uses
Wastewater
Treatment Use
Secondary
Containment Use
Oil Production Use
Separators are
exempt from all
SPCC requirements
in accordance with
§112.1(d)(6) and do
not count toward
facility storage
capacity.
Separators which are
used as part of a
secondary
containment system
and are not intended
for oil storage or use
are subject to
applicable secondary
containment
requirements and do
not count toward
storage capacity.
Separators are bulk
storage containers,
subject to the
provisions of
§§112.9(c) or
112.11(d), and count
toward the overall
facility storage
capacity. They are
not exempt.
Overview: SPCC Guidance for Regional Inspectors
Chapter 6: Facility Diagrams
 This chapter discusses:
– The purpose of the facility diagram
– Required and recommended elements of a
facility diagram
– Necessary level of detail
– Approaches for specific types of equipment
 Provides example facility diagrams
Overview: SPCC Guidance for Regional Inspectors
Chapter 7: Inspection, Evaluation,
and Testing
 Overview of the inspection, evaluation, and
testing requirements
 Specific requirements for:
– Integrity testing and visual inspection
– Brittle fracture evaluation
– Inspections of piping
– Flowline maintenance
Overview: SPCC Guidance for Regional Inspectors
Inspection, Evaluation, and
Testing, continued
 Specific cases
– Aboveground bulk storage container for
which the baseline condition is known
– Aboveground bulk storage container for
which the baseline condition is not known
– Deviation from integrity testing
requirements based on environmental
equivalence
 Summary of industry standards, code
requirements, and recommended
practices that apply to different types of
equipment
Overview: SPCC Guidance for Regional Inspectors
Role of the EPA Inspector
 Each chapter describes:
– Appropriate documentation that the
owner/operator should include in SPCC Plan
– What EPA inspectors should look for both in the
Plan and in the field to determine compliance with
the SPCC rule
 If the inspector questions the appropriateness of
alternative measures, he/she should fully
document all observations and other pertinent
information for further review by the regional
staff. Follow-up action by the EPA inspector may
include requesting additional information from
the facility owner or operator.
Overview: SPCC Guidance for Regional Inspectors
Appendices
A. Text of CWA 311(j)(1)(c)
B. Text of 40 CFR Part 112
C. Summary of Revised Rule Provisions
D. Sample Bulk Storage Facility SPCC Plan
E. Sample Production Facility SPCC Plan
F. Sample Contingency Plan
G. SPCC Inspection Checklists
H. Other Policy Documents
Overview: SPCC Guidance for Regional Inspectors
Sample Plans
 Example SPCC Plans for bulk storage and
oil production facilities
– Show appropriate format and level of detail
– Can be adapted to fit a facility’s sitespecific characteristics
 Example Contingency Plan
– Prepared according to the requirements of
40 CFR part 109
Overview: SPCC Guidance for Regional Inspectors
SPCC Inspection Checklists
 For EPA inspectors to record observations
during the site visit and review of the
SPCC Plan
 Provides room for inspector comments
and photos of the facility
 Helps achieve the goal of national
consistency in inspections
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Overview: SPCC Guidance for Regional Inspectors
Additional Information
 The Guidance Document and
additional information is
available on the U.S. EPA Oil
Program Web site,
www.epa.gov/oilspill
 Call the TRI, EPCRA,
RMP and Oil
Information Call Center
at 1-800-424-9346
Overview: SPCC Guidance for Regional Inspectors