T.I.H. Environmental

Self Certification

SPCC Self Certification, what is it? Self Certification is the process by which you use an EPA template and create your own SPCC. It is allowed for certain facilities meeting certain requirements. There are not very many facilities that can meet all the requirements and the EPA template is confusing and very time consuming. How time consuming you ask? It takes a company longer to properly fill out a self certification SPCC then it does to complete a regular SPCC and that is when the company knows what they are doing. 
What does that say for your time and your risk?

Be prepared for the following if you fill out the template yourself:

·                                 YOU get to sign off & be accountable to the EPA that YOU understand all the requirements of 40 CFR part 112, without further consultation?

·                               You get to certify under law that the inspections required for each above ground tank are performed daily, monthly & annualy.  
    Your inspections and test results must be maintained on-site.  
    Self Certification requires your inspection procedures to be written in accordance with industry standards.  Can you keep track of these ever changing records?

·                                 Did you know that self-certified plans do not allow for deviations in testing & inspection protocols, especially for brittle fracture assessments?  If the standards you use at your facility deviate from this, only a professional engineer or regional administrator can approve the deviation.

·                                 Do you know what a commitment plan is?  Are you prepared to write one in accordance with 40 CFR part 112?

·                                 Are you aware that secondary containment is the most critical part of your SPCC plan?  How do you know what the secondary containment requirements are and how much your containment can hold?  Can you calculate if your secondary containment is adequate and meets the regulation?

·                                 How do you know the EPA will allow your facility to use the EPA SPCC template? Only facilities meeting the SPCC Tier I requirements can self certify and use the EPA template plan.

How the EPA Template is Complicated:

                           Providing plan details can be difficult: You may have downloaded the form , but then found there were questions you couldn’t answer.
                           The template is not that simple.  Even this "short form" is more than 17 pages of unintelligible questions, so how much time will you devote to complete it? 

                         Accurate record keeping.  Do you have time to keep track of piles of papers & constantly update records. 
                        State & local law nuance.  The EPA SPCC template only meets the federal guidelines.  Any state law, BLM or environmental SPCC requirements are not covered by the plan.  You must make sure your plan complies with all state & federal guidelines.

A Responsible Company response is to:

·       * Complete and fill out the plan for you.

·        * Make sure the plan meets all federal SPCC requirements.

·        * Make sure your plan complies with State & Local requirements.

·        * Tailor your SPCC plan to the specifics of your facility.

·        * Keep your plan current with constantly changing regulations.

·        * Store your SPCC plan, facility & inspection records in a database and give you a data stick with your information on it. 
* If you have access to the web, your records should be organized & available to be sent to you when you need them.

·        A good company can automate your monthly inspection process & make sure your records are up to date.

How do I determine if I can Self Certify?            
If the total above ground storage is less than 10,000 gallons, owners may be able to self certify their SPCC plan.  
                       If the total capacity of all above ground storage added together exceeds 10,000 gallons, you need a full blown SPCC plan.

There are three levels of SPCC requirements for preparation, depending on the sizes of the storage containers located at the facility.

Tier I: SPCC Plan for a small facility that:  
                                        Has 10,000 gallons(238bbl) or less aggregate above ground petroleum storage capacity-includes all tanks, pipes and appurtances.  Any individual above ground petroleum storage container may be no greater than 5,000 gallons.  Within any twelve-month period, three years prior to the Plan certification date, there has been:

o                                                        No single discharge of petroleum to navigable waters or adjoining shorelines exceeding 1,000 gallons;

o                                                        No two discharges of petroleum to navigable waters or adjoining shorelines each exceeding 42 gallons.

Plan Requirements: Owner or operator may complete and self-certify plan template instead of a full Professional Engineer certified Plan. May also prepare and SPCC plan according to Tier II.

Tier II: Modest SPCC plan for a small to mid-sized facility that:

·                                 Has 10,000 gallons or less aggregate above ground petroleum storage capacity.

·                                 Has individual above ground petroleum storage container greater than 5,000 gallons.

·                                 Must meet all other Tier I discharge conditions.

Plan Requirements: Owner or operator may prepare self-certified Plan in accordance with requirements of 40 CFR, §112.7, in lieu of a Professional Engineer certified plan or may also prepare an SPCC plan according to all other facilities’ requirements.

However, the EPA states that you  have to have a PE certification for the parts of your self certified plan that deviate in any way from EPA regulations. This is for you to determine.

If so, what is the point of  self certification? 

All Other Facilities: Must have an PE certified SPCC!





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