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In This Issue

  1. Use of the Federal Drug Testing Custody and Control Form; Technical Amendment and Clarifications
  2. DOT Pipeline Compliance Workshop – October 19 – 21, 2010
  3. Special Speakers for DOT Workshop
  4. Proposed Pipeline Safety Legislation 111th Congress (2009-2010) S.3824
  5. RCP’s Web-Based Compliance Management Systems
  6. DIMP Integration
  7. Key Features
  8. Corporate Liability and Emergency Accident Notification (CLEAN) Act
  9. Control Room Management – Proposed Expedited Deadlines
  10. Control Room Management Services
  11. SPCC Rule Deadline Approaching
  12. ASME Pipeline Systems Division Update
  13. Damage Prevention Plans
  14. 2010 Damage Prevention Workshop
  15. Jurisdictional Determination
  16. PHMSA Control Room Management Implementation Workshop

SPCC Rule Deadline Approaching

All SPCC Plan holders are reminded of the November 10, 2010 deadline for compliance with the recently updated SPCC Rule. EPA has proposed to extend those deadlines by another year for most facilities, but that rulemaking has not been finalized. In general the current deadlines for SPCC-regulated facilities are as follows:

  • Facilities in operation on or before August 16, 2002, must amend as necessary and implement the Plan no later than November 10, 2010.
  • Facilities in operation after August 16, 2002, through November 10, 2010, must prepare and implement a Plan on or before November 10, 2010.
  • Facilities in operation after November 10, 2010, must prepare and implement a Plan before beginning operations. Oil production facilities must prepare and implement a Plan within six months after beginning operations.

SPCC Plan holders commonly utilize evaporation as a procedure for removal of rainwater from berms. Plan holders should be aware that inspectors will measure freeboard from the top of the standing water mark and not from the bottom of the berm. If your company utilizes the evaporization method, then berm capacity should include freeboard for the anticipated maximum volume of standing water as well as standard freeboard requirements. For additional information contact Jessica Roger.