Automation of SPCC Plan Preparation, Implementation, and Maintenance
The author’s approach was to develop a template for SPCC Plan preparation, implementation, and maintenance, considering the impact of the new EPA SPCC Plan regulations, efficient program design, and our experience in the information management field. The template needed to be sensitive to the scale and complexity of multiple facilities, often under a distributed management structure but under a common umbrella of pollution prevention responsibility. Within the information management area, plans needed to be able to reflect a common organization approach with pre-approved procedures, structure, and language, but yet have a data structure that would fit the range of applicable installations. The plans must be able to be updated by the local staff, approved by a responsible company official, and reviewed (if necessary) by a registered Professional Engineer. Finally, the structure of the plans must support the
implementation of a tracking system to help organizations monitor inspection and reporting requirements across multiple locations and to be ready with documentation on compliance with the plans during an agency inspection or compliance audit.