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Anyone else trying to fill out SPCC forms?
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Mike SE IL
Posted 11/4/2010 02:35 (#1421109)
Subject: Anyone else trying to fill out SPCC forms?



West Union, Illinois

All I can say is !@#$%&$*()^&^@!!!  This looks like it was written by a committee of lawyers.  Poor lawyers at that.  I have experience in dealing with code.  I was proficient enough at understanding "codeese" and "bureaucratese" to train others in how to interpret and follow the fuel gas codes.  That was a piece of cake.  Here is one excerpt:

 

  1. This facility meets the following qualification criteria (under §112.3(g)(1)):

    1. The aggregate aboveground oil storage capacity of the facility is 10,000 U.S. gallons or less; and

    1. The facility has had no single discharge as described in §112.1(b) exceeding 1,000 U.S. gallons and no two discharges as described in §112.1(b) each exceeding 42 U.S. gallons within any twelve month period in the three years prior to the SPCC Plan self-certification date, or since becoming subject to 40 CFR part 112 if the facility has been in operation for less than three years (not including oil discharges as described in §112.1(b) that are the result of natural disasters, acts of war, or terrorism); and

    2. There is no individual oil storage container at the facility with an aboveground capacity greater than 5,000 U.S. gallons.

  1. This Plan does not deviate from any requirement of 40 CFR part 112 as allowed by §112.7(a)(2) (environmental equivalence) and §112.7(d) (impracticability of secondary containment) or include any measures pursuant to §112.9(c)(6) for produced water containers and any associated piping;

 112.3(g)(1), 112.1(b), 112.7(d), (1) 112.7(a)(2), 112.9(c)(1) ...ARGH!!And when I try and look up these references to see what they say I find them with more references to other parts of the code than Keebler has chocolate chips.  Once I told the folks at the ASCS (Yes, it really was ASCS at the time) I wasn't signing any paperwork until they gave me a copy of all the references made in the contracts.  The CED told me he would do it if I wanted, but I better come in my pickup because it wouldn't all fit in my car. I finally relented.  But THIS!

Just to give you an idea, I looked up cfr40 part 112.7(a)(2) Here it is:

(2) Comply with all applicable requirements listed in this part. Except as provided in  § 112.6, your Plan may deviate from the requirements in paragraphs (g), (h)(2) and (3), and (i) of this section and the requirements in subparts B and C of this part, except the secondary containment requirements in paragraphs (c) and (h)(1) of this section, and  §§ 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), and 112.12(c)(11), where applicable to a specific facility, if you provide equivalent environmental protection by some other means of spill prevention, control, or countermeasure. Where your Plan does not conform to the applicable requirements in paragraphs (g), (h)(2) and (3), and (i) of this section, or the requirements of subparts B and C of this part, except the secondary containment requirements in paragraph (c) and (h)(1) of this section, and §§ 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), and 112.12(c)(11), you must state the reasons for nonconformance in your Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection. If the Regional Administrator determines that the measures described in your Plan do not provide equivalent environmental protection, he may require that you amend your Plan, following the procedures in § 112.4(d) and (e).

If I count correctly that one paragraph has 30 references to other paragraphs and parts of the regulations.   Maybe I am beginning to understand why nobody read the new healthcare bill through completely.   The only good thing I see is it is doubtful very many people have read and do understand the regs.

OK, enough ranting.  I, who never get headaches am taking a Tylenol for my headache and going to bed.

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