Saving Money with a Spill Prevention, Control, and Countermeasure (SPCC) Plan
Implementing a comprehensive Spill Prevention, Control, and Countermeasure (SPCC) plan at your facility could end up saving you thousands of dollars in the event of an oil spill.
An SPCC plan is a federally mandated requirement by the U.S. Environmental Protection Agency (EPA) for facilities involved in oil storage, processing, refining, or consumption. Its purpose is to prevent oil spills into navigable waters, adjacent shorelines, or other natural resources, while also providing guidance for spill response, regular training, countermeasure planning, and best management practices. By adhering to this plan, you not only comply with SPCC requirements but also have a written procedure to boost oil spill prevention and protect your facility from an emergency response situation.
What to Know About the Clean Water Act
The Clean Water Act (CWA) is a significant piece of legislation protecting our waterways from pollution, including oil spills. The CWA prohibits the discharge of oil into navigable waters unless authorized by a permit. It can impose hefty fines for non-compliance, making it crucial for facility owners to understand the regulations to avoid unintentional violations.
Who is Required to Have an SPCC Plan?
A SPCC plan is an essential tool to help facilities prevent accidental oil discharges and prepare proper response measures. The SPCC rule requires a plan for any facility with storage tanks for petroleum products that have the potential to discharge oil.
Although there are some exclusions, the Clean Water Act requires a SPCC plan as part of your facility documentation if you have:
A tank that is not already regulated by another program
An aboveground storage tank that exceeds 1,320 gallons or any total storage capacity of containers (55-gallon drum or larger) that exceeds 1,320 gallons
If your qualified facility has less than 10,000 gallons of total capacity and no single storage tank greater than 5,000 gallons, you can have a self-certified SPCC plan. However, if your storage capacity exceeds 10,000 gallons or the facility has a single tank of 5,000 gallons or more, a licensed engineer must complete your SPCC plan.
What Does a Good SPCC Plan Look Like?
Complying with SPCC regulations will contribute to oil pollution prevention and will better prepare the facility and its owner/operator to deal with an incident if one occurs. In addition, SPCC plans aid local and regional response authorities to better understand the potential hazards and response capabilities in their area.
Here is a template for a comprehensive SPCC plan:
Detailed descriptions of the facility and its operations
Describe your facility’s operations that involve oil storage and controls on oil drainage and discharge.
Inventory of all oil storage tanks and containers
Identify all oil storage containers on site, including aboveground and underground storage, with the potential to release over 55 gallons.
Discharge scenarios and preparedness measures
In the event of a spill, there should be information to help you identify if it is a reportable or nonreportable release. Spill kits and spill control devices become part of the SPCC plan to reduce the initial spread of a spill and offer more time for a qualified professional to respond.
Comprehensive spill response and reporting procedures
Have a reliable spill response contractor and qualified professionals listed in case of emergency events. In some cases, we have seen spill response contractors on site within an hour of a reportable spill. Without a contractor in place to help, it can be unclear who to call first and it may take 6-24 hours to get someone on site.
Prevention measures
Manage a thorough recordkeeping system for regular inspections and maintenance. This includes periodic inspection, overfill prevention, secondary containment systems, and procedures for the proper handling of products and wastes.
Professionally certified or prepared
For a facility requiring a stamped SPCC plan, a professional engineer can best evaluate where a spill could happen and where it can go. For self-certified facilities, an environmental professional can assist with completing the documentation and developing a spill response plan. Having this information readily available can save you time during an emergency response.
Up-to-date procedures
Review and revise your SPCC plan every 5 years or following significant changes in facility operations or oil storage.
Preventative Solutions
In the event of a substantial spill at a facility, there are effective solutions for cleanup and remediation. However, it's far better for clients to steer clear of these costly scenarios by taking preparation measures. Should a spill occur at your site, it's a chance to enhance your response plan for any potential future incidents.
You can proactively minimize spill impacts by:
Understanding your building systems: Identify any systems that are located near areas that could be affected by a fuel release. Knowledge of how your building's drainage, ventilation, and other systems work can play a critical role in spill prevention and hazard containment.
Locating stormwater drains: A stormwater drain that leads to a retention pond or an offsite location can be a direct path for a fuel spill to travel. It is possible to install oil-water separator units within a storm drain near fuel tanks so if a spill were to occur, it could contain the entire release or reduce the downstream impact. Engineered controls like secondary containment and oil-water separators can significantly prevent oil spills from going further and entering waterways such as groundwater and surface water.
Monitoring liquid sensors: You can install liquid sensors on the ground near a day tank so that if there is any instance of a release, the sensor alarm will immediately notify you.
Investing in prevention rather than dealing with the aftermath of an oil spill is your best bet. Regular maintenance, systematic checks, and the implementation of effective containment measures are key. These steps, combined with thorough training of your staff on response protocols and proper handling of potential pollutants, will ensure that your facility stays compliant and minimally impactful to the environment.