On the front page of the October Environmental Compliance Newsletter from BLR (www.blr.com) was a timely article: Compliance Tip: 10 Common SPCC Violations.
Here are just a few of the 10 common violations as reported by BLR:
- The SPCC Plan does not have a signature
- The SPCC Plan is not certified by an engineer (when applicable)
- Personnel not properly instructed in spill prevention procedures
- Compatibility of tanks with the materials stored in the tanks not discussed in plan.
Remember, the SPCC rules apply to those who have the capacity to store 1,320 gallons or more of oil (and other regulated substances). So if you have a 2,000 gallon tank and it is only a quarter full, it is still regulated. The deadline to comply with the SPCC amendments is November 10, 2011.
If you have questions about SPCC plans contact Matthew Schroeder, PE (firstname.lastname@example.org) at 248-932-0228.
SPCC: Spill Prevention Control and Countermeasure Plan