CAPACCIO prepared a Spill Prevention, Control and Countermeasures (SPCC) Plan for the client’s Massachusetts site. To prepare this plan, CAPACCIO submitted a request to the client for SPCC-related information, including training records, tank testing records, bulk oil storage quantities and locations, oil transfer practices, spill history, location of oil-filled operational equipment, facility plans, and other general operational information. CAPACCIO reviewed topographic and aerial photographic information for the site. CAPACCIO conducted a site visit to review activities regulated under the SPCC Plan requirements. In particular, CAPACCIO reviewed facility operations where oil was stored, transferred, and used to assess the SPCC requirements for each activity. In addition, CAPACCIO met with personnel with knowledge of oil handling and response activities.
CAPACCIO prepared the SPCC Plan based on information provided by the client and information collected during the site visits. A “first draft” was provided for review and comment along with a list of outstanding issues requiring additional information or follow-up. The client was responsible for addressing SPCC Plan deficiencies, including building modifications, alternative storage locations and procedural modifications to address spill response. Upon receipt of comments, CAPACCIO issued a “final draft” SPCC Plan to the client for final review and consequently issued a final SPCC Plan prepared and certified in accordance with 40 CFR 112.