Why we do a SPCC Plan review at 5 years
It was reviewed every 3 years up until 2002. The purpose is to keep this document current with your operations and SPCC Plan regulatory changes.
Do you have to do a 5-year review of your SPCC Plan? No if the following apply.
• You have had no changes in oil storage capacities and/or secondary containment, or
• Facility has had no changes to water flow or drainage paths or
• Facility operations have had no changes in the handling of petroleum products.
• The EPA has not made any changes to the requirements of the SPCC Plan requirements such as SPCC Plan preparation, or engineering requirements such as tank inspections, containment requirements. Their guidance manual and interpretations should be reviewed.
After the 5-year cycle of Professional Engineer review if you do not have them update, the PE is no longer responsible for the SPCC Plan being prepared in accordance with Oil Pollution Prevention Act or the SPCC Plan requirements. It is the management official that decides the review is not necessary. Your decision means you will not be able to claim that you were unaware of the EPA changes in the SPCC Plan requirements. Because this could mean citations and fines, this decision to not do a review should be with the official that will be writing the checks.