SPCC plan five-year reviews, read against the facility's records for the owner and the engineer to decide.

A review file starts with the plan as last certified, its facility diagram and its container table. Then comes whatever the facility kept since: records of tanks and drums bought, moved or retired, integrity test and inspection reports, drainage logs from the diked areas, briefing sign-in sheets and any spill notes. Your staff walk the site, hold the diagram up against what they see, and write up the review and the changes for the owner and, when one is needed, the Professional Engineer.

For the test, AI reads copies of finished review files and drafts the review record: each container in the plan matched to what the records and site notes show now, each change listed with its date and the document that shows it, the inspection and briefing records found or missing, and the review statement with its signature line and its "will" or "will not" left blank. Whether any change is a technical amendment, and whether the plan still fits the facility, stays with the people who sign. Your reviewer reads each draft beside the review your firm delivered.

The review clock and the amendment clock run apart. Under 40 CFR 112.5(b), the plan gets a review and evaluation at least once every five years, counted from when the facility became subject to the rule or, for one operating on or before August 16, 2002, from when its last review was due. The owner documents it and signs a statement at the start or end of the plan, or in a log or appendix, and the rule offers the words: "I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result." Where field-proven prevention and control technology would significantly reduce the likelihood of a discharge, the amendment follows within six months of the review and is put in place within six months after that. Separately, 112.5(a) asks for an amendment within six months of any change that materially affects the potential for a discharge, whenever it happens. The draft dates every change it finds, so your reviewer can see which ones fell between reviews.

The rule's own examples are where the reading starts. Section 112.5(a) names commissioning or decommissioning containers; replacing, rebuilding or moving them; rebuilding, replacing or installing piping; construction or demolition that might alter secondary containment; a change of product or service; and revised operating or maintenance procedures. A technical amendment needs a Professional Engineer's certification under 112.3(d), in which the engineer attests, among other things, that he or his agent visited and examined the facility; it never relieves the owner of carrying out the plan. EPA's published answers say a non-technical change, one that doesn't call for good engineering practice, needs no PE, and neither does a review where nothing changed, since the owner decides whether a change calls for a technical amendment. Its guidance for regional inspectors treats facility diagram changes as administrative. The draft sets each change beside the 112.5(a) example it most resembles and labels none of them technical or non-technical.

Capacity counts move with every container. Among its conditions, the rule covers a facility whose aboveground oil capacity tops 1,320 U.S. gallons, counting only containers of 55 gallons or more, or whose completely buried capacity tops 42,000 gallons. A container drops out of the count as permanently closed only when its liquid and sludge are gone, its lines are disconnected and blanked off, its valves other than vents are closed and locked, and a sign on it gives the date of closure; a tank drained and left connected still counts. For drums and totes, EPA's inspector guidance accepts an estimate, with the example of a drum area holding anywhere from 10 to 100 drums written up as 550 to 5,500 gallons. The draft adds capacity up again from the container records, lists every closure record missing one of those four steps, and checks the drum range against what the site notes counted.

Self-certified plans have edges of their own. A facility with 10,000 gallons or less aboveground, and no single discharge over 1,000 gallons or two over 42 gallons within any twelve months in the three years before self-certifying, may certify its own plan; Tier I also means no container over 5,000 gallons. The owner then certifies its own technical amendments, except that an amendment touching a part an engineer certified, such as an alternative offering environmental equivalence or a finding that secondary containment is impracticable, goes back to a PE. Growing past 10,000 gallons, or past 5,000 in one container at a Tier I facility, starts a six-month clock to move to a different kind of plan. Under 112.4, the same discharge sizes call for a report to EPA's Regional Administrator within 60 days. The draft totals capacity and lists every recorded spill with its volume and date, and leaves the tier, and any report, to the owner and the engineer.

Inspection records are the other half of the file. Section 112.7(e) wants inspections and tests run under written procedures, with records signed by the supervisor or inspector kept with the plan for three years, and 112.8(c)(6) adds integrity testing of each aboveground container on a schedule set by industry standards, with comparison records. EPA's inspector guidance recommends keeping formal test and inspection reports for the life of the container. In its summary of the editions it cites, API 653 sets certified inspections 5 to 30 years apart with monthly owner inspections, and STI SP001 sets intervals by tank size and configuration with monthly, quarterly and yearly owner inspections. Oil-handling staff also need a discharge prevention briefing at least once a year. The draft lists, container by container, the last integrity test, the owner inspections found for each period and the briefings on file. Your reviewer will check every container, capacity, date and record against the review you delivered, and confirm the draft called nothing technical, adequate or compliant.

When your reviewer says yes, each review that comes due gets the same reading for about 30 days.

Every draft goes to your staff to check against the site walk, then to the owner to sign the review statement. Any technical amendment still goes to the Professional Engineer to certify, and your firm delivers the review the way it does today.

Drafts and finished reviews stay side by side for the whole month. A second job begins only after that, and only if you pick one.