When certifying a technical change to an existing SPCC Plan, does the professional engineer (PE) have to inspect and certify the entire plan or only the amended portion?
Except as provided in 40 CFR
for qualified facilities, a PE must certify all technical amendments to an existing Spill Prevention, Control, and Countermeasure (SPCC) plan (see
). The PE must only inspect and certify the portion of the plan that has been technically amended, rather than the entire plan. Since the certifying PE may not have been involved in certifying the Plan originally, the PE's certification and attestation only applies to that particular technical amendment.
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