PROGRAM DEVELOPMENT AND OVERSIGHT
Rule 40 CFR Part 112 is part of the U.S. Environmental Protection Agency’s oil spill prevention program and was published under the authority of Section 311(j)(1)(C) of the Federal Water Pollution Control Act (Clean Water Act) in 1974. This rule covers any facility that stores, processes, refines, uses, or consumes oil and is non-transportation-related. This includes onshore / offshore oil well drilling / production facilities, oil refining / storage facilities, certain waste treatment facilities, pipeline systems used to transport oil exclusively within the confines of a facility, and more. HRL is specialized in providing subject matter expertise in accordance with this rule.
At HRL, it is our goal to ensure full SPCC compliance by working with operators to develop a thorough, all-encompassing SPCC plan. Our services include:
SITE INSPECTIONS
HRL has completed hundreds of SPCC inspections throughout the country. All containment and storage vessel dimensions are carefully measured. Detailed photographs of the entire facility are taken, including the specification tags on all equipment, as pertaining to the SPCC rule. Surface water flow directions are mapped along with areas of water collection (retention ponds) and areas where leaks may be more likely to occur. Any leaking or at-risk equipment is noted and promptly brought to the attention of the operator so that repairs can be made swiftly. Moreover, the relative positions of all relevant equipment and pipelines are mapped. Facilities that HRL has inspected include:
SPCC PLANS / Diagrams
HRL has assisted with drafting and implementing SPCC plans. These plans outline an extensive list of categories, including spill response procedures, training procedures, conformance with other regulations (BLM, USFS, etc.), maintenance programs, contingency plans, and appropriate staff certifications. A full equipment inventory encompassed by the Rule is included in the plan. Additionally, a detailed facility diagram is incorporated into the plan (or a set of diagrams, depending on the size of the facility or the scope of the plan). These highly detailed diagrams meet all the criteria listed by the Rule and are easy to follow and understand, compared to many standard engineering diagrams.
From initial inspection through the drafting and implementation of the final SPCC plan, HRL’s professional staff takes pride in our commitment to accuracy, detail, and comprehensiveness in ensuring that our clients’ facilities are following all applicable regulations.