COMPLIANCE INFO_2021 - Laserfiche WebLink

Home Browse Search

IE13 SFq U.S. ENVIRONMENTAL PROTECTION AGENCY .W SPCC FIELD INSPECTION AND PLAN REVIEW CHECKLIST .qlo, TIER I QUALIFIED FACILITIES Overview of the Checklist This checklist is designed to assist EPA inspectors in conducting a thorough and nationally consistent inspection of a facility's compliance with the Spill Prevention, Control, and Countermeasure (SPCC) rule at 40 CFR part 112. It is a required tool to help federal inspectors (or their contractors) record observations for the site inspection and review of the SPCC Plan. While the checklist is meant to be comprehensive, the inspector should always refer to the SPCC rule in its entirety, the SPCC Regional Inspector Guidance Document, and other relevant guidance for evaluating compliance. This checklist must be completed in order for an inspection to count toward an agency measure (i.e., OEM inspection measures or GPRA). The completed checklist and supporting documentation (i.e. photo logs or additional notes) serve as the inspection report. This checklist addresses requirements for Tier I Qualified Facilities that meet the eligibility criteria set forth in §112.3(g)(1). Separate and standalone checklists address the requirements for: Onshore facilities including Tier II Qualified Facilities (excluding oil drilling, production and workover facilities); Onshore oil drilling, production and workover facilities including Tier II Qualified Facilities as defined in §112.3(g)(2); and Offshore drilling, production and workover facilities Tier I Qualified Facilities must meet the rule requirements in §112.6 and other applicable sections specified in §112.6. The checklist is organized according to the SPCC rule. Each item in the checklist identifies the relevant section and paragraph in 40 CFR part 112 where that requirement is stated. • Sections 112.1 through 112.5 specify the applicability of the rule and requirements for the preparation, implementation, and amendment of SPCC Plans. For these sections, the checklist includes data fields to be completed, as well as several questions with "yes," "no" or"NA" answers. • Section 112.6 includes requirements for Tier I qualified facilities. • Section 112.7 includes general requirements that apply to all facilities (unless otherwise excluded). Attachments • Attachment A is a checklist for Sections 112.8 and 112.12. This checklist specifies requirements for spill prevention, control, and countermeasures for onshore facilities (excluding oil production facilities). • Attachment B is a checklist that specifies requirements for spill prevention, control, and countermeasures for onshore oil production facilities (112.9 provisions) and onshore drilling and workover facilities (112.10 provisions) • Attachment C is for recording information about containers and other locations at the facility that require secondary containment. • Attachment D is a checklist for documenting the tests and inspections the facility operator is required to keep with the SPCC Plan. • Attachment E is a checklist for oil spill contingency plans following 40 CFR 109. Unless a facility has submitted a Facility Response Plan (FRP) under 40 CFR 112.20, a contingency plan following 40 CFR 109 is required if a facility the owner or operator of a facility with qualified oil-filled operational equipment chooses to implement alternative requirements instead of general secondary containment requirements as provided in 40 CFR 112.7(k). Attachment F is for recording additional comments or notes. • Attachment G is for recording information about photos. The inspector needs to evaluate whether the requirements in the checklist are addressed adequately or inadequately in the SPCC Plan and whether it is implemented adequately in the field (either by field observation or record review). For the SPCC Plan and implementation in the field, if a requirement is addressed adequately, mark the"Yes" box in the appropriate column. If a requirement is not addressed adequately, mark the "No" box. If a requirement does not apply to the particular facility or the question asked is not appropriate for the facility, mark as "NA". Discrepancies or descriptions of inspector interpretation of"No"vs. "NA" may be documented in the comments box subsequent to each section. If a provision of the rule applies only to the SPCC Plan, the "Field" column is shaded. Space is provided throughout the checklist to record comments. Additional space is available as Attachment F at the end of the checklist. Comments should remain factual and support the evaluation of compliance. Tier I Qualified Facilities Page 1 of 8 June 2014