The Environmental Protection Agency (EPA) has amended the dates by which facilities must prepare or amend their Spill Prevention, Control, and Countermeasure (SPCC) Plans, and implement those Plans to November 10, 2010. Under the amended §112.3(a):

• the owner or operator of a facility that was in operation on or before August 16, 2002, must maintain his SPCC Plan, make any necessary amendments to the Plan and fully implement it by November 10, 2010
• while the owner or operator of a facility that came into operation after August 16, 2002, but before November 10, 2010, is required to prepare and implement an SPCC Plan on or before November 10, 2010.
• Under the amended §112.3(b)(1), the owner or operator of an onshore or offshore facility that becomes operational after November 10, 2010, and could reasonably be expected to have a discharge as described in § 112.1(b), must prepare and implement a Plan before beginning operations.

Under amended §112.3(c), an owner or operator of a mobile facility is required to maintain his SPCC Plan, but must make any necessary amendments and implement it on or before November 10, 2010. The owner or operator of an onshore or offshore mobile facility that becomes operational after November 10, 2010, and could reasonably be expected to have a discharge as described in §112.1(b), must prepare and implement an SPCC Plan before beginning operations.

The Agency believes that an extension of the compliance date is appropriate because it provides the owner or operator of a facility the opportunity to f ully understand all of the regulatory amendments offered by revisions to the SPCC rule promulgated since July 2002. This extension will allow the regulated community approximately 16 months beyond the previous compliance date of July 1, 2009 to make changes to their facilities and to their SPCC Plans necessary to comply with the revised SPCC requirements.

Editor’s Note: Here comes the zinger!

Furthermore, because EPA has not yet decided how to proceed on the December 2008 rule amendments, the Agency believes that this compliance date extension provides sufficient time for the Agency to review those comments and to promulgate any additional revisions that result from this review. The Agency expects to promulgate final revisions to the December 5, 2008 amendments, if any, in November of 2009 and is therefore choosing a compliance date that is approximately one year from the expected publication date of those revisions.

Editor’s Translation: “We extended the deadlines to give us time to figure out what we REALLY are going to require you to do. We’ll let you know in November. Until then, just keep maintaining the plans you have.”

What does it mean when RCP says they are

“Professional Engineers”?

We do a lot of consulting, and are proud of our accomplishments in that area . . . but as they say, all you need to do in order to be a “consultant” is to call yourself one. Being a professional engineer, on the other hand, is strictly regulated and requires demonstration of technical expertise and experience. RCP’s tag line is “Professional Engineers. Regulatory Experts. Trusted Partners.” We couldn’t say the “Professional Engineers” part unless it was true and it is. While RCP is best known for its expertise with regulations and regulatory compliance, we also provide excellent engineering services including integrity management, risk assessment, and expert witness testimony. Our employees do the nitty-gritty engineering analysis to evaluate mechanical integrity issues, develop remediation programs, and coordinate repair and replacement programs. At the same time, they are demonstrated experts in regulatory compliance issues and management. There just isn’t another company that provides RCP’s unique mixture of regulatory expertise and real-world engineering and implementation experience.

What does that mean to you? RCP can provide a broad range of integrity management, compliance management, and process safety management services to your company – increasing your quality of service while decreasing your overall costs and simplifying your contract administration. If you haven’t asked, you’ll never know what problems we could solve for you!