Annual Facility Site Inspections
The EPA requires that for every SPCC plan that you implement that you perform at least annually, a detailed site inspection, which covers the basics of spill contingency and mitigation.
When a company is audited by the EPA they are ask for a minimum of 3 years of annual inspections to be reviewed at the time of the audit. Not only does the EPA review your inspections for all applicable sections, now they're looking to see if the inspections cover the flowlines and wellhead leak references.
They want to know that the flowlines, at least the ones on top of the ground, are at a minimum visually inspected for signs of rupture or contamination. When the lines are underground they want to know that the contact points where the lines are visible, usually at the end points, are inspected for problems.
Failure to provide Annual Facility Inspections will result and deficiencies in the audit, and they will refer you to a enforcement officer to collect fines and verify you've completed your inspection. Even though you are fined for not having them, they will require that you get a new Annual Facility Inspection and show proof of the new annual inspection. For those who continue to not comply they will hold the company in contempt of the rules, and an enforcement officer will eventually fine the company on a daily basis until the information is updated. The officer who performed the initial audit will no longer have anything to do with the enforcement of the fines and remediations.
Annual Inspections are the least expensive of all the compliance products that we offer at Spill Plan Reports. They start as little as $75 and go up to $225 for Commercial SWD Facilities.