If your gin had a contract with TEEMCO for an SPCC plan, or for Tier II reporting, you will probably be contacted by Jessica O’Hern from Affordable Compliance Engineering. Jessica contacted our office Monday to let us know they had acquired the data from the SPCC plans that TEEMCO had done. Since they already have all the data, they can probably re-certify your SPCC plan at the end of the five year period without having to come back to your gin and re-work all the data. This is probably a very good option if your petroleum storage systems have not changed since the plan was originally written.
Tier II plans have to be submitted annually. If you were relying on TEEMCO to submit your Tier II report, and have not found another company to submit your Tier II reports, then Affordable Compliance Engineering may be a good option for this as well.
TCGA has not done any work with Affordable Compliance Engineering, so we don’t have any experience with this company, but it certainly does make sense to have then recertify your SPCC plan if they are already in possession of the data. After visiting with them over the phone and reviewing their firm, they seem like a firm that would be worth trying out. Please let us know how your experience goes if you decide to have them to your SPCC plan renewal, or do your Tier II reports.
As always, if you have questions about any of this information, please give your TCGA office a call.