EPA issued a Notice on May 25th regarding SPCC interpretations and associated negotiations as a follow-up to their March 31, 2004 SPCC Stakeholder meeting in Washington DC. Although this information is basically repeating what RCP and EPA has already told you, it does provide more detail. The notice provides some clarifications developed by the Agency during the course of settlement proceedings. These clarifications were presented at the Stakeholder meeting and were also summarized in RCP’s April 2004 DOT Pipeline Newsletter. The complete Federal Register article can be downloaded from RCP’s website here through the SPCC Gateway.
EPA has also recently added several documents to their Oil Program website related to this issue including their summary of and slide presentations from the Stakeholder meeting, and the Settlement Agreement with API and Marathon Oil Company.
The recent Notice also announces the availability of a letter issued by EPA’s Office of Solid Waste and Emergency Response (OSWER) to the Petroleum Marketers Association of America (PMAA). This letter provides some additional detail on two of the issues that were covered in the meeting and summaries: integrity testing of shop-built tanks and security fencing. The letter can be downloaded from RCP’s website here through the SPCC Gateway.
We are still waiting on EPA to follow through with the statement below, made during the Stakeholder meeting and in their summary:
“EPA is still a few weeks away from determining an implementation strategy, but once finalized, the Agency will communicate the strategy and issue guidance through the form of an OSWER directive to the regional offices. In addition, the Oil Program is developing checklists and sample plans that will be provided to the regions, in order to increase the level of national consistency.”
Meanwhile, RCP has the expertise and is ready to help you meet the current requirements of the SPCC Rule and to prepare for the upcoming deadlines of August 17, 2004 (update SPCC Plans) and February 18, 2005 (implement updated Plans). RCP has developed SPCC Plans for dozens of clients, large and small, and is qualified to provide that service to your company efficiently and effectively. Please call Rick Hood at 713/655-8080 to discuss any details