COMMON DEFICIENCIES IN SPCC PLANS
We looked at recent
EPA enforcement actions and identified a number of SPCC Plan deficiencies. The list below is some of the more general
types that may not be applicable to all facilities. In addition, other types of violations not
listed below may also apply to a facility’s specific operations.
1.
Plan not
certified by a professional engineer (PE)
2.
No
management approval of plan
3.
Plan not
maintained on-site or not easily accessible
4.
No
evidence of 5-year review of plan by owner/operator
5.
No plan
amendment(s) if the facility has had a change in design, construction,
operation, or maintenance that affects the facility’s discharge potential
6.
Amendment(s)
not certified by a professional engineer
7.
Plan
does not follow sequence of the rule and/or cross-reference not provided
8.
Plan
does not discuss additional procedures/methods/equipment not yet fully
operational
9.
Plan
does not discuss alternative environmental protection to SPCC requirements
10.
Plan has
inadequate or no facility diagram
11.
Inadequate
or no description of drainage controls
12.
Inadequate
or no description of countermeasures for discharge discovery, response, and
cleanup
13.
No
contact list and phone numbers for response and reporting discharges
14.
Plan has
inadequate or no information and procedures for reporting a discharge
15.
Plan
does not discuss and facility does not implement appropriate containment/diversionary
structures/equipment (including truck transfer areas)
16.
Impracticability
has not been clearly denoted and demonstrated in plan.