Challenge: To maintain compliance with EPA’s Oil Pollution Prevention Regulation upon completion of a plant expansion.
Solution: As part of a plant expansion, INTERA prepared a revised Spill Prevention, Control, and Countermeasure (SPCC) Plan in accordance with the requirements of EPA’s Oil Pollution Prevention regulation for oil storage tanks, oil filled manufacturing equipment, electrical transformers, truck loading/unloading stations, and railcar unloading racks. An INTERA licensed professional engineer visited and inspected the facility, including the plant expansion project. To prepare and certify the revised SPCC Plan, we described facility operations; evaluated the distance to navigable waters and the use of retention ponds, a sluice gate, and a pumping system for secondary containment structures; identified potential spill scenarios with failure type, flow rate, maximum volume released, flow direction, and active and passive containment measures; prepared detailed inspection, testing, and recordkeeping procedures; identified personnel training and spill prevention measures; described tank design, materials of construction, and fail-safe engineering features; described facility transfer and loading/unloading operations; described security measures in-place to prevent releases; and described discharge response and notification procedures.
Results: The expanded plant operations remain in compliance with the EPA’s Oil Pollution Prevention Regulation.
