The Oil Pollution Prevention Regulation (40 CFR Part 112) requires that an SPCC Plan be prepared in accordance with good engineering practices and be approved by a person with the authority to commit the resources necessary to implement the SPCC Plan. The SPCC Plan should clearly address the following three areas:
Each SPCC Plan must be unique to the facility. Development of a unique SPCC Plan requires detailed knowledge of the facility and the potential effects of any oil spill. Each SPCC plan, while unique to the facility it covers, must include certain standard elements to ensure compliance with the regulations. For example:
JGD is an experienced SPCC Plan provider. We are knowledgeable in compliance standards for 40 CR-112, the Federal Law that mandates SPCC plans. We maintain relationships in the industry and among regulators to assure our clients of successful results in their regulated facilities. In 2008, we formed a joint venture with Regulatory Consultants, Inc. to provide Owners, Installers and other Engineering Firms to easily and accurately produce quality, compliant SPCC Plans.
The potential regulated community under 40 CFR-112 is estimated to exceed 100,000 currently non-compliant facilities. With a de-facto grace period for enforcement ending November, 2010, there is a vast amount of work to do—far more than any single firm can handle. JGD Associates has assessed the real challenge as the need for more trained Professional Engineers capable of producing compliant SPCC plans. As a result, it has developed a Professional Development course on SPCC sold through www.PDHEngineer.com . This course provides the necessary background and proven methodologies for qualified engineers to become part of the solution in this tremendous undertaking, and fulfills a portion of mandated annual PDH requirements for registrants.