In the 2008 Amendments to the SPCC Rule, EPA provided a template for the owner or operator of a Tier I qualified facility to create an SPCC Plan. Does EPA require a Tier I qualified facility to use the template in 40 CFR Part 112, Appendix G? Does EPA allow a Tier I qualified facility to modify the template if they use it to create a Plan?
The owner or operator of a Tier I qualified facility may use the template in Part 112, Appendix G to comply with the streamlined requirements for Tier I qualified facilities; however, EPA emphasizes that the use of this template is optional. When the owner of operator of a qualified facility does not follow the Appendix G template, then an equivalent Plan must be prepared in writing that meets all applicable requirements as described in §112.6(a)(1). If the owner or operator chooses to use the Appendix G template, it may be used as a model and modified as necessary to meet the facility-specific needs, as long as all applicable rule requirements are included in the SPCC Plan and a cross-reference is provided.
Additionally, a Tier I qualified facility owner or operator may choose to prepare and implement a Plan meeting the Tier II qualified facility requirements in §112.6(b) or prepare and implement a full PE-certified SPCC Plan instead of a self-certified one (§112.6(a)(1)).