An integrated paper company, with multiple operations in California and throughout the west coast, required updates to their Spill Prevention, Control, and Countermeasure (SPCC) Plans, which were originally put in place in 2002. The SPCC plan for each facility was based on a common template which was customized based on the unique characteristics at each location. However, EPA’s SPCC regulation has undergone multiple revisions and updates since inception and our client requested ALG to review their SPCC plans and perform the necessary updates for compliance. A compressed time schedule was required, and resourceful project design and management were essential to contain costs.
ALG began with evaluating the facilities current SPCC plans and oil containment capacities. A site visit to each facility was conducted, where together with plant management, ALG verified all the oil containing equipment, internal tank inspection procedures and spill prevention measures. This review confirmed that oil containment capacity for each facility was less 10,000 gallons, EPA’s maximum capacity threshold for a Tier 1 facility. As such, ALG determined that a more cost effective and efficient approach would be to use the EPA approved Tier 1 SPCC plan template for each facility rather than update the current customized SPCC plans. The main advantage to this approach is the assurance that all the required elements of the SPCC regulation are addressed in the plan, and going forward plant managers could perform the required SPCC monitoring and recordkeeping and updates. An additional benefit is that regulatory inspectors typically are familiar with the Tier 1 plan and therefore, inspections should proceed much more smoothly compared to inspection of a customized SPCC plan.
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ALG successfully assisted our client in transitioning from a customized SPCC plan to an EPA approved Tier 1 SPCC plan for each of their facilities. ALG worked with EPA Region IX to ensure that all elements of the SPCC regulation were addressed and implemented correctly and provided training for the facility plant managers to ensure that the facility is familiar with the plan and all the requirements of the SPCC regulation.