Embed Size (px)
Citation preview
www.blr.com or www.hrhero.com For CD and other purchasing information, contact customer service at: 800-274-6774 or E-mail: [email protected]
© 2013 BLR ® and HR Hero® —Business & Legal Resources and HR Hero. All rights reserved. These materials may not be reproduced in part or in whole by any process without written permission.
Understanding SPCC: Get Your Questions Answered
by the Person Who Wrote the Rule
Thursday, June 13, 2013 1:30 p.m. to 3:00 p.m. Eastern
12:30 p.m. to 2:00 p.m. Central 11:30 a.m. to 1:00 p.m. Mountain 10:30 a.m. to 12:00 p.m. Pacific
Presented by:
Mark Howard USEPA
Office of Emergency Management
Understanding SPCC:Get Your Questions Answered by the Person Who Wrote the Rule
Presented by:
Mark W. HowardUSEPA
Office of Emergency Management
June 13, 2013
EPA has made every effort to ensure the accuracy of this presentation. However, please note:
This presentation is for informational purposes only and does not constitute Agency guidance.This presentation does not bind the Agency and does not govern Agency actions in the event of any conflict with a statute, regulation, policy, guidance, or other interpretation of the law by EPA.
Always refer to the SPCC rule and official Agency guidance found at
www.epa.gov/oilspill
HistorySPCC Basic OverviewSPCC EnforcementCommon ViolationsQ&A
Prevention Spill Prevention, Control, & Countermeasure
PreparednessFacility Response PlansArea Contingency PlansNational Preparedness for Response Exercise ProgramNCP Subpart J Product ScheduleGIS Mapping
ResponseNational Contingency Plan National Response System
Federal, State, Local, Tribal
Statutory authorities:Federal Water Pollution Control Act (Clean Water Act)Oil Pollution Act of 1990
Regulations pursuant to these laws:National Oil and Hazardous Substances Pollution Contingency Plan (NCP) 40 CFR part 300Prevention, Preparedness, and Response regulations (SPCC & FRP) 40 CFR part 112Discharge of Oil (Sheen Rule) 40 CFR part 110
Rivers and Harbors Act of 1899Prohibited the discharge of pollutants or refuse into or on the banks of navigable waters without a permit
Oil Pollution Act of 1924Prohibited the discharge of refuse and oil into or upon coastal or navigable waters of the United States
Federal Water Pollution Control Act (FWPCA) 1948
Water Quality Improvement Act (WQIA) of 1970 Provided the federal government broad authority to:
Clean up oil spillsRequire a polluter to notify the proper authority of a oil dischargePay the cost of cleanup and Establish requirements to prevent oil discharges.
Federal Water Pollution Control Act (FWPCA) 1972Carried forward much of WQIA section 11
Principal federal law protecting navigable waters and adjoining shorelinesSec. 311 addresses oil pollution and hazardous releases.Provides EPA and the US Coast Guard with authority for preventing, preparing for and respond to spillsImplemented through the NCP and Oil Pollution Prevention regulations.
10
Effective since 1974
Establishes:Oil discharge prevention proceduresEquipment requirementsContainment requirements
Requires written PlanDetail equipment, workforce, procedures, and training to prevent, control, and provide adequate countermeasures to a discharge of oil
Issued July 17, 2002; effective August 16, 2002Based on three proposals (1991, 1993, 1997)Performance‐based: provides flexibility in meeting many of the oil discharge prevention requirements
Environmental EquivalenceImpracticability Determinations
Includes new subparts outlining requirements for various classes of oil (pursuant to EORRA)Amends the requirements for SPCC Plans
Streamlined the regulatory requirements Brief overview of revised rule provisions:
Owners/operators of facilities that have an oil storage capacity of 10,000 gallons or less of oil and meet other qualifying criteria may self‐certify their SPCC PlanAlternative to general secondary containment requirement, without requiring a determination of impracticability, for facilities with qualified oil‐filled operational equipment and meet other qualifying criteriaDefines and exempts motive power containers Exempts mobile refuelers from sized secondary containment requirements for bulk storage containersRemoves SPCC requirements for animal fats and vegetable oilsProvided an indefinite extension for farms
• Published in the FR on December 5, 2008
• Originally scheduled to go in effect February 3, 2009
• Addressed areas highlighted in the EPA Regulatory Agenda and the 2005 OMB report ‘‘Regulatory Reform of the U.S. Manufacturing Sector’’
• Nicknamed “SPCC II”• Focused on farms and
production
Finalize certain December 2008 amendments without changeRemove certain provisions from the December 2008 final ruleProvide technical corrections to certain provisions of the December 2008 amendments
Exclusion for oil production facilities and farms from loading/unloading rack requirementsAlternative qualified facility eligibility criteria for an oil production facilityExemption for certain produced water containers
Spill Prevention, Control, and Countermeasure rulePart of the Oil Pollution Prevention regulation (40 CFR part 112)
Includes requirements for Facility Response Plans (FRPs) for certain facilities which pose a greater threat to waterways and the environment
Purpose – To develop plans designed to prevent oil discharges from reaching the navigable waters of the U.S. and adjoining shorelines
Rule Section
Topics
Subpart A Applicability, definitions, and general requirements for all facilities and all types of oil
Subpart B Requirements for petroleum oils and non-petroleum oils, except those covered in Subpart C
Subpart C Requirements for animal fats and oils and greases, and fish and marine mammal oils; and vegetable oils, including oils from seeds, nuts, fruits, and kernels
Subpart D Response requirements (FRP rule)
§112.1 General applicability of the rule§112.2 Definitions of terms used in the rule§112.3 Requirement to prepare an SPCC Plan§112.4 Amendment of SPCC Plan by RA§112.5 Amendment of SPCC Plan by owner or operator§112.6 Qualified Facilities [2006 amendment]§112.7 General requirements of all facilities§§112.8 – 112.12 Additional specific requirements for different types of facilities and
different types of oils§112.20 Facility Response Plans§112.21 Facility response training and drills/exercises
Appendix A Memorandum of understanding between the Secretary of Transportation and the Administrator of the Environmental Protection Agency
Appendix B Memorandum of understanding among the Secretary of the Interior, Secretary of Transportation, and Administrator of the Environmental Protection Agency
Appendix C Substantial harm criteriaAppendix D Determination of a worst case discharge panning
volumeAppendix E Determination and evaluation of required response
resources for facility response plansAppendix F Facility‐specific response planAppendix G Tier I template
“Compliance dates” refer to the deadline for the owner or operator of an SPCC regulated facility to implement post‐2002 SPCC requirements. The delay of effective date of the 2008 amendments did not impact the compliance date for the SPCC rule provisions.Many stakeholders were confused by the two actions changing the effect date of the 2008 rule provisionsThe regulated community thought the compliance date was January 14, 2010 (which was actually the new effective date of 2008 action)To further complicate matters, EPA proposed a final action to change the compliance date in early 2009
A facility starting operation… Must…
On or before August 16, 2002• Maintain existing SPCC Plan• Amend and implement the SPCC Plan no later than November 10, 2011.
After August 16, 2002 through November 10, 2011
• Prepare and implement the SPCC Plan no later than November 10, 2011.
After November 10, 2011 • Prepare and implement an SPCC Plan before beginning operations.
*The November 10, 2010 compliance date applies to drilling, production or workover facilities, including mobile or portable facilities, located offshore or with an offshore component or an onshore facility that is required to have and submit FRPs
**The November 10, 2011 compliance date applies to all other facilities (less farms)
Owner/operator makes the initial decision on applicability of SPCC regulations to the facilityDoes the facility meet the applicability criteria (volumes of oil, expectation to spill to waterway)?
No requirement to submit SPCC Plan to EPA for approvalEPA does not formally “approve” or disapprove of SPCC PlanPlan is required upon inspection during regular workday
The SPCC Rule applies to a facility that meets the following criteria:
Drills, produces, gathers, stores, processes, refines, transfers, distributes, uses, or consumesoil and oil products; and
Is non‐transportation related (i.e. facility is not exclusively covered by DOI or DOT); andCan reasonably be expected to discharge oil in quantities that may be harmful into or upon the navigable waters of the U.S. or adjoining shorelines; andMeets capacity thresholds
• Aboveground storage > 1,320 gallons; or• Completely buried storage > 42,000 gallons
1
2
3
4
5
Containers with a capacity <55 gallonsFacilities subject solely to other agency jurisdictionsUnderground storage tanks subject to UST technical requirementsUSTs at nuclear power generation facilitiesWastewater treatment facilitiesPermanently closed containersMotive power containers
Hot‐mix asphalt (HMA)Residential heating oil containers (ASTs and USTs)Pesticide application equipmentIntra‐facility gathering lines subject to the requirements of 49 CFR part 192 or 195Milk and milk product containers and associated piping and appurtenances
§112.1(d)
Prepare Plan in accordance with Good Engineering Practices
Full approval of management to implement Plan
Follow sequence of Section 112.7, or use a cross‐reference section
112.7 has a number of new response oriented provisions
SPCC regulations requires preparation and implementation of a written Plan to address:
Operating procedures for routine handling of products to prevent a discharge of oilDischarge or drainage control measures to prevent a discharge of oilCountermeasures to contain, clean up, and mitigate an oil spillMethods of disposal of recovered materialsContact list and phone numbers of company, contract response personnel, and National Response Center
For facilities with >10,000 gallons of oil, Plans are required to be certified by a Professional Engineer (PE)For facilities with > 1,320 up to 10,000 gallons of oil, can opt to self‐certify SPCC Plans
Details to follow (Qualified Facilities)This is optional alternative to PE certificationTwo tiers of certification
A qualified facility is a smaller oil storage facility that is eligible for streamlined regulatory requirements
Self‐certified SPCC Plan instead of one reviewed and certified by a Professional EngineerStreamlined integrity testing requirementsStreamlined facility security requirements
Must meet eligibility criteria EPA’s recent amendments would divide this group of facilities into tiers
Requirements described here would apply to “Tier II” facilitiesAdditional relief would be provided to “Tier I”
Facility must have 10,000 gallons or less in aggregate aboveground oil storage capacityWill lose eligibility if facility increases capacity > 10,000 gallons
For the 3 years prior to Plan certification, or since becoming subject to the rule if it has operated for less than 3 years, the facility must not have had:
A single discharge of oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, or Two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 U.S. gallons within any 12‐month period.
EPA’s 2008 amendments create a subset of Qualified Facilities.
Facilities meeting the criteria described earlier are “Tier II” qualified facilities.Facilities meeting additional criterion are “Tier I” qualified facilities and are subject to further streamlined requirements.
The 2009 rule amendments provide clarifications to the rule language associated with this set of facilities, and corrections of typographical and formatting errors in the Tier I template.
2008
/200
9 A
men
dmen
ts
2008
Am
endm
ents
Meet the Tier II qualified facility eligibility criteria:
10,000 gallons or less in aggregate aboveground oil storage capacityFor the 3 years prior to Plan certification, or since becoming subject to the rule if it has operated for less than 3 years, the facility must not have had:
A single discharge of oil to navigable waters exceeding 1,000 U.S. gallons, or Two discharges of oil to navigable waters each exceeding 42 U.S. gallons within any 12‐month period
‐ AND ‐Maximum individual oil storage container capacity of 5,000 U.S. gallons
2008
Am
endm
ents
“Tier I qualified facilities” have:The least complicated operations and facility characteristicsMay have few low capacity oil containers and some mobile/portable containers, few oil transfers, little to no piping.
A Tier I qualified facility would have the option to complete an SPCC Plan template (in Appendix G to 40 CFR part 112) in lieu of a full SPCC Plan. The choice for Tier I or Tier II is optional if the qualifying criteria are met.The 2009 rule amendments provided corrections of typographical and formatting errors on the Tier I template, and removed language on the template associated with the provisions that were removed from the rule.
2008
/200
9 A
men
dmen
ts
Template is designed to be a simple SPCC Plan. Includes only the requirements that should apply to this tier of regulated facilities. Eliminates and/or modifies certain requirements and provisions that generally do not apply to facilities that store or handle smaller volumes of oil.
Template is found in Appendix G to the SPCC rule.
2008
/200
9 A
men
dmen
ts
Certified by a licensed PELicensed in state or state with reciprocity
PE familiar with 40 CFR Part 112
PE or agent visited facility
In accordance with good engineering practicesConsider applicable industry standards
In compliance with regulations
Inspection and testing procedures are established
Plan is adequate for facility
Complete review and evaluation of PlanOnce every 5 years from the date facility becomes subject to the ruleIf a facility was in operation on or before 8/16/2002, five years from the date of your last review required by the ruleDoes not always require a PE
Amend Plan within 6 months to include more effective prevention and control technologyImplement ASAP, but no later than 6 months of amendmentTechnical amendments
SPCC Plan must be maintained at facility if manned 4 hours/per day or more, or at nearest field office if manned less than 4 hours/per day
Allowance of usual and customary business records to serve as records of inspection or tests
Conduct inspections and tests in accordance with written procedures developed by the facility or by the engineer who certifies the facility Plan
Keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years
Allows deviations from most technical requirements of the rule when:
Equivalent environmental protection is provided and reasons for non‐compliance explained
Does not include secondary containment, training, recordkeeping, and administrative provisions of the rule
Train oil‐handling personnelOperation/maintenance of prevention equipmentDischarge procedure protocolsApplicable pollution control laws, rules, and regulationsGeneral facility operationsContents of the facility SPCC Plan
Designate person accountable for discharge prevention and who reports to facility managementSchedule/conduct at least one briefing/year:
Known discharges and failures, malfunctioning components, new precautionary measures
Provide appropriate secondary containment and/or diversionary structures or equipment to prevent a discharge (from tanks, drums, totes, piping, etc.) to “navigable waters of the U.S. and adjoining shorelines”The entire system (walls and floor) must be capable of containing oil so that a discharge from containment will not occur until cleanup occurs§112.7(c)
Clarified that the general secondary containment requirement is intended to address the most likely oil discharge from any part of a facilityUse of active and passive secondary containment, such as spill kits, allowed
Modifies §112.7(c) to expand the list of example prevention systems for onshore facilities
Additional examples: drip pans, sumps, and collection systems
New text: “… In determining the method, design, and capacity for secondary containment, you need only to address the typical failure mode, and the most likely quantity of oil that would be discharged. Secondary containment may be either active or passive in design.”
“General” Secondary Containment requirement applies to the following examples:
Nurse tanksMobile refuelersOil‐filled equipment (transformers, manufacturing equipment, etc.)Transfer areas
Piping runs/racks, manifolds, etc.Truck loading/unloading areas (not loading rack)
No specific‐sized volume requirementSizing based on typical spill size not container size
Specific minimum size requirement for secondary containment for:
Bulk storage containersMobile or portable bulk storage containers*
The secondary containment must be sized to contain the largest single oil compartment or container plus “sufficient freeboard” to contain precipitation
* Certain mobile portable containers (tanker trucks and nurse tanks) are only required to have general secondary containment
No container should be used for the storage of oil unless its oil and construction are compatible with the oil stored and the conditions of storage, such as pressure and temperature, etc.For bulk storage tank installations, provide secondary containment for the entire capacity of the largest single container with sufficient freeboard for precipitation
Overfill Protection. Provide at least one of the following devices:
High liquid level alarmsHigh liquid level pump cutoffDirect audible or code signal communication between container gauger and pumping stationFast‐response system for determining liquid level of each bulk storage container, with person present to monitorRegularly test liquid level sensing devices (follow manufacturers specifications)
49
Typical characteristics:Permanent structure to load or unload a tank trunk or tank car that is located at a regulated facilityEquipment may be comprised of piping assemblages, valves, loading arms, pumps, or a similar combination of devicesThe system is necessary to load or unload tank trucks or tank carsThe system may also include shut‐off devices and overfill sensors
§112.7(h)
Requirements only apply when loading racks are presentOil production facilities and farms typically do not have transfer equipment that meets the definition of loading rackThe presence of a loading rack at a facility does not automatically covert all other transfer equipment to a loading rack (PMAA settlement)
§112.7(h)
51
Look for the loading arm
Must comply with general secondary containment requirementsMust also comply with sized secondary requirements
Containment system must hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility
Provide an interlocked warning light or physical barrier system, warning signs, wheel chocks or vehicle brake interlock system in the area adjacent to a loading/unloading rack, to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines.
§112.7(h)(2)
Prior to filling and departure, closely inspect lowermost drain and all outlets of vehiclesTighten, adjust, or replace, as necessary, to prevent discharge while in transit
§112.7(h)(3)
Loading/Unloading AreasLoading/Unloading Areas
If there is not a loading rack, but a loading area then 112.7(c) general containment is required (no specific size volume required)
You determine amount most likely to be spilled, then provide secondary containment for that volume
Equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device
Not considered a bulk storage containerDoes not include oil‐filled manufacturing equipment
Examples: hydraulic systems, lubricating systems, gear boxes, machining coolant systems, heat transfer systems, transformers, circuit breakers, electrical switches, other systems containing oil solely to enable the operation of the device
Alternative to the general secondary containment requirements for qualified oil‐filled operational equipment:
Prepare an oil spill contingency Plan and a written commitment of manpower, equipment, and materials Have an inspection or monitoring program to detect equipment failure and/or a discharge (§112.7(k))
Must meet eligibility criteria
For the 3 years prior to Plan certification, or since becoming subject to the Rule if it has operated for less than 3 years, the facility must not have had:
– A single §112.1(b) discharge of oil from any oil-filled operational equipment exceeding 1,000 U.S. gallons; or
– Two §112.1(b) discharges of oil from any oil-filled operational equipment each exceeding 42 U.S. gallons within any 12‐month period.
The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters of the U.S. and adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for the purposes of this reporting requirement.
60
Applies to:Large (field‐constructed or field‐erected) and small (shop‐built) aboveground bulk storage containersAboveground bulk storage containers on, partially in (partially buried, bunkered, or vaulted tanks) and off the ground wherever located Aboveground bulk storage containers storing any type of oil
Examples: mobile/portable containers, drums, totes
§§112.8(c)(6) and 112.12(c)(6)(i)
Env
iron
men
tal E
quiv
alen
ce
61
Test and inspect each aboveground container for integrity on a regular schedule and whenever material repairs are madeFlexibility to determine, in accordance with industry standards:
Appropriate qualifications for personnel performing tests and inspectionsFrequency and type of testing and inspections that take into account container size, configuration, and design
§§112.8(c)(6) and 112.12(c)(6)(i)
Env
iron
men
tal E
quiv
alen
ce
62
Frequently inspect for signs of deterioration, discharges, or accumulation of oil inside diked areas
§§112.8(c)(6) and 112.12(c)(6)(i)
Env
iron
men
tal E
quiv
alen
ce
63
Requirements are distinct from, and in addition to, the requirement to regularly test each aboveground bulk storage container for integrityIntended to be a routine walk‐around by the owner/operatorMust occur frequently to detect signs of deterioration, discharges, or accumulations of oil inside diked areasTypically conducted by properly trained facility personnel Records for integrity tests and frequent visual inspections –usual and customary business practices will suffice
§§112.8(c)(6) and 112.12(c)(6)(i)
Env
iron
men
tal E
quiv
alen
ce
Drums and totes (portable containers): Periodic visual inspections, as long as sized secondary containment provided; typically monthly, can be weekly, etc.Tanks: Periodic visual inspections by the owner/operator plus formal inspections based on the industry integrity testing standard that is used. Visual inspections are typically performed monthly, can be weekly, etc.Piping: Periodic visual inspections by the owner/operator, typically monthly, can be weekly, etc.Fuel transfer areas: Visual inspections by the owner/operator during transfers, typically monthly, can be weekly, etc.
Certain manmade features may be taken into consideration in determining how to comply with SPCC requirementsSPCC Plan preparer can consider:
The ability of building walls and/or drainage systems to serve as secondary containment for a container
Freeboard for precipitation not necessary if container is indoors
Indoor conditions that reduce external corrosion and potential for discharges, to develop a site‐specific integrity testing and inspection program
Buried piping installed after August 16, 2002 must be:
Protectively wrapped and cathodically protected; orSatisfy the corrosion protection provisions for piping in 40 CFR parts 280 or 281 (state program)
• Requirement applies to all soil conditions• Exposed piping must be inspected for corrosion• Take corrective action if corrosion damage
Conduct regular inspections of all aboveground valves, piping, and appurtenances
Assess general condition of items such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces
Conduct integrity and leak testing of buried piping at time of installation, modification, construction, relocation, or replacement
Cap or blank‐flange piping
Signs to prevent pipe strikes
Properly designed piping supports
(continued)
69
SPCC/FRP violations (statutory/regulatory)Clean Water Act (CWA) §311(j) and 40 CFR part 112
Discharge violations (statutory)CWA §301(a) discharge of a pollutant without a permit, or out of compliance with the terms of the permitCWA §311(b)(3) discharge of a harmful quantity of oil or a hazardous substance
Failure to notify violations (criminal)CWA §311(b)(5)
70
CWA §311(b)(6)(B) provides two classes of administrative penalties:
Class I Penalties• Up to $16,000 per violation• Up to a maximum penalty of $37,500
Class II Penalties• Up to $16,000 per day for each day the violation continues• Up to a maximum penalty of $177,500
71
Civil judicial penalties are assessed under CWA §311(b)(7):
For SPCC or FRP regulatory violations, up to $37,500 per day of violationImportant to note there is no cap and a per day violation
Federal government represented by DOJ
Penalties for 311(b)(3) oil/hazardous substance spills ‐‐under 311(b)(7)
Up to $37,500 per day of violation, or Up to $1,100 per barrel of oil or unit of reportable quantity "discharged"
Unpermitted discharge, under 309(d):Up to $37,500 per day for each day of violation
Criminal penalties under 309(c) also may apply for a discharge violation of 301(a) or 311(b)(3) if the violation was negligent or knowing.
Typical Compliance IssuesFrom Around the Ten EPA
Regions
VERY COMMON!!!
Commonly found at facilities that did not know that they were regulated
Small facilitiesFarmsConstruction sitesSmaller storage facilities
Common Violation
PE certifies that the facility’s equipment, design, construction, and maintenance procedures used to implement the Plan are in accordance with good engineering practices.PE certification must be completed in accordance with law of the state in which the PE is workingGenerally certification includes:
NameRegistration number and StateDate of certificationPE seal affixed to Plan
Common Violation
77
Owner/operator does not have records of inspections or tests
Common to hear that they do inspections, but not write them down
No Integrity testing records/program
Common Violation
79
Common Violation
80
Common Violation
81
Common Violation
82
Common Violation
83
Common Violation
85
This is the containment drain valve.
Common Violation
86
Common Violation
87
Common Violation
88
Common Violation
89
Common Violation
90
Common Violation
91
Common Violation
Proper maintenance and inspection of
containment structures
Common Violation
Report all oil discharges to navigable waters of the U.S. and adjoining shorelines to NRC at 1‐800‐424‐8802Federal government's centralized reporting center, which is staffed 24 hours a day by U.S. Coast Guard personnelAny person in charge of a vessel or an onshore or offshore facility must notify NRC immediately after he or she has knowledge of the dischargeNRC relays information to EPA or U.S. Coast Guard depending on the location of the incidentAn On‐Scene Coordinator evaluates the situation and decides if federal emergency response action is necessaryFederal notification does not ensure State and Local notification
Report to the EPA Regional Administrator (RA) when there is a discharge of:
More than 1,000 U.S. gallons of oil in a single discharge to navigable waters of the U.S. and adjoining shorelinesMore than 42 U.S. gallons of oil in each of two discharges to navigable waters of the U.S. and adjoining shorelines within a 12‐month periodWhen making this determination it is the amount of the discharge in gallons that reaches navigable waters of the U.S. and adjoining shorelinesAn owner/operator must report the discharge(s) to the EPA Regional Administrator within 60 days
Name of the facility;Your name;Location of the facility;Maximum storage or handling capacity of the facility and normal daily throughput;Corrective action and countermeasures you have taken, including a description of equipment repairs and replacements;An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary;The cause of such discharge as described in §112.1(b), including a failure analysis of the system or subsystem in which the failure occurred;Additional preventive measures you have taken or contemplated to minimize the possibility of recurrence; andSuch other information as the Regional Administrator may reasonably require pertinent to the Plan or discharge
Send to the appropriate agency or agencies in charge of oil pollution control activities in the State in which the facility is located a complete copy of all information you provided to the Regional AdministratorUpon receipt of the information such State agency or agencies may conduct a review and make recommendations to the Regional Administrator as to further procedures, methods, equipment, and other requirements necessary to prevent and to contain discharges from your facilityAs stated earlier this may trigger an inspectionThis requirement is designed to identify SPCC Plan failures and ineffective implementation of the Plan
EPA’s SPCC web pagehttp://www.epa.gov/emergencies/content/spcc/index.htm
EPA Oil Spill and Emergency Management web pageswww.epa.gov/oilspillwww.epa.gov/emergencies
HOTLINE: Superfund, TRI, EPCRA, RMP, and Oil Information Center
(800) 424‐9346 or (703) 412‐9810TDD (800) 553‐7672 or (703) 412‐3323www.epa.gov/superfund/resources/infocenter
REGION SPCC COORDINATORS AG CONTACTS
1CT, RI, MA, NH, VT, ME
Alex Sherrin (617) 918‐[email protected]
Rob Koethe (617) 918‐[email protected] Szylvian (617) 918‐[email protected]
2NJ, NY, PR, VI
Larry D’Andrea (732) 906‐[email protected]
Kristina Heinemann (212) 637‐[email protected]
3PA, WV, VA, MD, DC
Arlin Galarza‐Hernandez (215) 814‐3223galarza‐[email protected]
John Butler (215) 814‐[email protected]
4KY, NC, TN, SC, MS, AL, GA, FL
Ted Walden (404) 562‐[email protected]
Denise Tennessee (404) 562‐[email protected]
5MN, WI, MI, IL, IN, OH
Barbara Carr (312) 886‐[email protected]
Tom Davenport (312) 886‐[email protected] Winn (312) 886‐[email protected]
6NM, TX, OK, AR, LA
Don Smith (214) 665‐[email protected] Perry (214) 665‐[email protected]
Randy Rush (214) 665‐[email protected]
7NE, KS, IA, MO
Alan Hancock (913) 551‐[email protected]
Karen Flournoy (913) 551‐[email protected] Frizzell (913) 551‐[email protected] Duncan (913) 551‐[email protected]
REGION SPCC COORDINATORS AG CONTACTS
8MT, ND, SD, WY, UT, CO
Melissa Payan (303) 312‐[email protected]
Jennifer Meints (303) 312‐[email protected]
9CA, NV, AZ, HI, Guam, American Samoa, Northern Marina Islands
Pete Reich (415) 972‐[email protected] Witul (415) 972‐[email protected]
Kerry Drake (415) 947‐[email protected] Hodge (415) 972‐[email protected]
10WA, OR, ID, AK
WA: Mike Sibley (206) 553‐[email protected], ID: Richard Franklin (503) 326‐[email protected]: Matt Carr (907) 271‐[email protected]
Karma Anderson (206) 553‐[email protected]
HQ‐Office of Emergency Management:
Mark Howard (202) 564‐[email protected] Gioffre (202) 564‐[email protected] Swackhammer (202) 564‐1966swackhammer.j‐[email protected]
Ag Center:Ginah Mortensen (913) 551‐[email protected] Galloway (913) 551‐[email protected]
HQ‐Office of Civil Enforcement:
David Drelich (202) 564‐[email protected] Brantner (202) 564‐[email protected]
HQ‐Office of Compliance: Dan Chadwick (202) 564‐[email protected]
Disclaimers
*This webinar is designed to provide accurate and authoritative information about the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional services. *This webinar provides general information only and does not constitute legal advice. No attorney-client relationship has been created. If legal advice or other expert assistance is required, the services of a competent professional should be sought. We recommend that you consult with qualified local counsel familiar with your specific situation before taking any action.
Mark Howard is an environmental scientist with the EPA Office of Emergency Management, in the Regulation and Policy Development Division in Washington D.C. Howard is the Spill Prevention, Control and Countermeasure (SPCC) Technical Team Leader and national project manager for the Inspector’s Training Program, the Oil Program Technical Guidance Workgroup, the Upstream (production) Technical Workgroup, and the On-Scene Coordinator Readiness Training Program. He is also the lead technical member of the SPCC rulemaking workgroup. Prior to his work with the federal government, Howard worked for 10 years as a state responder and aboveground storage tank inspector with the Commonwealth of Virginia’s Department of Environmental Quality.
Mark Howard
Speaker Biography
