MAINTAINING SPCC PLAN COMPLIANCE
Posted on March 2, 2017
Many believe SPCC Plans are prepared and certified by a Professional Engineer (PE) and then can simply sit on a shelf for five years until time for the plan to be updated and certified again. As the regulation states, this is not how to remain in compliance. While it is true that once every five years the plan must be reevaluated and recertified, it is also true that within six months of any change (examples noted below in the excerpt of the regulation), the plan, maps, and inventory must also be updated and recertified by a PE.
(40 CFR Part 112.5)
(a) Amend the SPCC Plan for your facility in accordance with the general requirements in §112.7, and with any specific section of this part applicable to your facility, when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge as described in §112.1(b). Examples of changes that may require amendment of the Plan include, but are not limited to: commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures at a facility. An amendment made under this section must be prepared within six months, and implemented as soon as possible, but not later than six months following preparation of the amendment.
Many industrial facilities experience qualified changes that require a recertification by a Professional Engineer on a regular basis. Changes of product, moving a container, commissioning a new drum storage area, or removing a container all require a Professional Engineer to recertify the plan.
The best way to avoid being out of compliance is for the qualified visual inspector to note any changes during the required monthly inspections. If during the monthly inspection, the inspector notes a change, it should trigger a plan revision within 6 months.
It should be noted that most inspectors only walk an efficient route from one container to another during their monthly inspections and can simply never see new containers or storage locations that are added in other parts of the facility. A solid Management of Change (MOC) procedure or communication is necessary to account for these additions. At the time of the necessary recertification, it is highly recommended that a facility-wide inventory be performed to assure total compliance