Baron has recently had the opportunity to assist a facility through the final stages of a DPCC renewal: the Technical Review and Facility Audit conducted by the NJDEP program manager for the facility. As Baron previously reported, the annual DPCC audit has now become a triennial audit (once every 3 years). The delay between the submission of a DPCC renewal plan and the actual Technical Review is currently taking between 18 months and 2 years.
The basis for the triennial audit is the NJDEP checklist. It should be noted that the checklist is in an unusual order and inspectors typically bounce around through the document during the evaluation instead of reviewing it line by line.
Several issues were raised during the audit that Baron was not expecting. The facility was asked for a list of all equipment repairs to valves and tanks as well as to secondary containment units. The inspector was not pleased that the data had to be pulled from the facility’s Computerized Maintenance Management System (CMMS). He requested that the facility should maintain these records in a special logbook or file so it is available immediately upon request. The delay in obtaining these records from the database was less than 2 hours. The inspector wanted to view each loading/unloading area to ensure wheel chocks were present.
The program manager chastised the facility for making minor administrative changes over the lifetime of the current plan without DEP approval. While he was lenient in this instance, he made it very clear that this was something that should not occur.
If a facility switches from API 653 to SP-001 for the inspection of steel tanks (which many facilities are doing), the facility must ensure that an external inspector, certified in SP-001 inspections, completes an inspection prior to the expiration of the previous inspection timeline to initiate the SP-001 method. Many inspectors are certified in both methods, however a facility should verify this prior to switching methods.
In the Technical Review, the facility was asked to present an updated letter of credit despite the fact that the letter of credit specifically indicated that it was automatically renewed each year unless cancelled in writing. An up to date signed agreement with the outside contractor for spill cleanup was also required.
Records were reviewed for three years in the following areas:
New employee orientation and training
Annual refresher training
Records were reviewed for ten years in the following areas:
Process area checklists
Loading/unloading checklists
Equipment repairs and upgrades to tanks, valves and secondary containment
Tank inspections (monthly, annual and external)
Security item inspections (fences, locks, etc.)
Discharge/leak history of facility
Overall, the process was fairly smooth and the program manager did not appear to be “out for blood” on small issues where it was clear the facility was attempting to do the right thing. The program manager spent almost 2 full days at the facility and then there was substantial follow up to ensure all items were closed to avoid a letter of technical deficiency being issued.