Do I need an SPCC Plan?If you handle petroleum products, food oils, solvents,
or anything else that would cause a sheen if spilled on water,
and you store a total of 1,320 gallons or more above ground on
your facility, you are required to have an SPCC plan. (No one
is exempt!)
What is an SPCC Plan? SPCC stands
for spill prevention, containment and countermeasures . This plan
is in report form with procedures and diagrams that the owner
agrees to follow in the event of a spill or release that has the
potential to reach navigable waterways.
How much is this going to co$t me? Depending
on your operations, aboveground storage capacity and fluid handling
volumes, the cost will be as little as $1,500 to in excess of
$10,000 for larger, more complicated facilities. A lot depends
on what documentation is in place and what procedures are already
followed.
Do I need to have a PE sign my plan?
No, within certain parameters, you can self-certify if
you have under 10,000 gallons of above-ground storage capacity.
You can also write your own will, paint your own house, change
your own oil and plow your own snow. Many people choose to give
these jobs out to those who are prepared to handle them.
If I already have an SPCC Plan, am I
covered? It's a good start. What you have to look at is
whether it is reflective of the current state of affairs at your
facility. If changes in fluid handling capacities, procedures,
locations, drainage, etc. have occurred since your last plan was
enacted, you are not in compliance. If your tanks and fittings
are not in compliance, neither are you.
What is the deadline for Implementation?
You have to have an SPCC plan in place by November 10,
2010 . Remember, though that it will take time to complete your
plan, there will be a rush prior to the deadline, and you may
have to have some physical plant modifications to comply with
the plan. It's best not to wait.
Why? What is the penalty for not having
an SPCC plan? Penalties for non compliance can be up to
$25,000 per day for violators.
OK. What do I have to do? Call JGD
Associates, Inc. (440) 933-6825 and ask for advice on how to
get started. There is no charge for this initial contact.
Call or contact JGD Associates for your executive consultation
