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  • When must an incident investigation be initiated for Program 2 and 3 processes?

    When must a stationary source owner or operator begin conducting incident investigations as required under 40 CFR §68.60 (for Program 2 processes) or 40 CFR §68.81 (for Program 3 processes)? For both Program 2 and Program 3 processes, the incident investigation must be initiated as soon as possible, but not…

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  • Breaking a process into separate units to comply with prevention program requirements

    Do I have to do my hazard review, process hazard analysis, or other prevention activity on the whole process or can I break it into separate units? Once you have determined that you have a covered process, you can divide the covered process any way you want to implement the…

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  • Applicability of compliance audit provisions to emergency response programs

    I have a Program 2 covered process and a Program 3 covered process at my stationary source, and I am required to conduct compliance audits certifying that I have evaluated compliance with my prevention program requirements at least every three years (40 CFR Sections 68.58 and 68.79). Do these provisions…

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  • What does "materials of construction" mean?

    What does “materials of construction” apply to and how do I find this information? You must document the materials of construction for all process equipment in a covered process. For example, you need to know the materials of construction for process vessels, storage vessels, piping, hoses, valves, and flanges. Equipment…

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  • Is a PE required to review an SPCC Plan if it has not changed?

    Under the 2002 regulations, is a PE required to review the SPCC Plans at the end of a 5-year SPCC Plan cycle if no changes have occurred at the facilities? No. It is the responsibility of the owner or operator to document the completion of a review and decide whether…

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  • PE certifying an SPCC plan in a different state

    Except as provided in 40 CFR §112.6 for qualified facilities, a licensed Professional Engineer (PE) must review and certify an SPCC Plan for it to be effective to satisfy the requirements of Part 112 (§112.3(d)). When reviewing and certifying a facility’s SPCC Plan, must the PE be licensed in the…

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  • How did EPA amend the requirements for animal fats and vegetable oils in 2006?

    In December 2006, EPA removed the following SPCC requirements for the following specific types of animal fat and vegetable oil facilities: Requirements for onshore oil production facilities (Section 112.13) Requirements for onshore oil drilling and workover facilities (Section 112.14) Requirements for offshore oil drilling, production, or workover facilities (Section 112.15)…

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  • Rainwater in containment system of SPCC regulated farm

    What do I do with rainwater that accumulates in my containment system for a farm regulated by the Spill Prevention, Control, and Countermeasure (SPCC) rule? Check the rainwater for any oil, and if no oil is present, this can be released. If there is oil in the water, this water…

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