EI has been providing SPCC plans and related services for 20 years and is eminently qualified in this area. Our specialists have written papers, presented at conferences, and participated in national seminars on the topic. We have provided services to utilities, municipalities, major industries, and commercial property owners. With that, EI’s professionals have the background and experience to provide any service associated with SPCC Rule compliance, including:
- SPCC Development
- Facility Response Plan (FRP) development per 40 CFR 112.20
- Compliance Reviews
- Tank Inspections per the STI Standard
- Expert Consultation and Opinions
History of SPCC
The Federal Government first developed rules in 1974 regulating above ground oil storage tanks. The Exxon Valdez accident prompted the United States Congress to pass the Oil Pollution Control Act of 1990. Following the Ashland oil spill in Floreffe, Pennsylvania, where 750,000 gallons of oil discharged into the Monongahela River, the EPA, not waiting for Congress, began making significant changes to the “Spill Prevention, Control and Counter-Measure (SPCC) Rule.”
The major 2010 changes to the SPCC Rule include the following:
- Broadening of the definition of “oil.”
- Including oil-filled operational equipment, e.g., transformers, lube systems.
- Including requirements for loading/unloading areas and racks.
- Clarification on secondary containment requirements.
- Allowing exemptions for “Qualified Facilities.”
- Required formal inspections and testing as prescribed by API, STI, or others.
Our Experience
The Steel Tank Institute (STI) wrote the standard for testing shop-fabricated tanks. EI’s tank inspectors are STI-Certified and are ready to assist with storage tank inspection and testing compliance
In addition to SPCC requirements, 40 CFR 112 also contains regulations for the applicability, development, and implementation of Facility Response Plans (FRP) for facilities that pose a particular oil spill risk, e.g., a total storage capacity of 1,000,000 gallons. EI is well versed in this area as well having prepared and updated dozens of FRPs.
EI’s SPCC experts can answer any SPCC questions or provide the required services to ensure your compliance with the rules.
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Ladder Safety – A Critical but Overlooked Safety Program
Ladder safety is critical in the workplace to prevent accidents and ensure the safety of employees. Each year in the U.S. there are more than 164,000 emergency room-treated injuries and 300 deaths that are caused by falls from ladders. An estimated 81% of fall injuries treated in hospital emergency rooms involve a ladder. In most situations, ladders were used improperly. The most frequent ladder injuries include broken bones and head injuries. This is why it is crucial for employers to comply with ladder safety requirements set by regulatory bodies like OSHA and ANSI.
