Monday, December 8, 2014

COMMON DEFICIENCIES IN SPCC PLANS



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.