Sometimes oil or oil-based products are spilled into bodies of water or onto land, endangering both the environment and human health. To ensure that facilities are taking appropriate actions to prevent oil discharges, the EPA put the Spill Prevention, Control, and Countermeasure (SPCC) rule into effect, which mandates creating and implementing an SPCC plan.
While an SPCC plan is an environmental compliance mechanism, it is also a useful document for oil discharge avoidance and response. The expenses of fines, lawsuits, and the cleanup itself is often excessive, far outweighing the cost of spill prevention. A reliable, comprehensive plan can be extraordinarily valuable.
What exactly is a Spill Prevention, Control, and Countermeasure plan? An SPCC plan meets the stipulations of the SPCC rule – which you can find within the SPCC regulations (Title 40, Code of Federal Regulations, Part 112). It is an environmental preparedness document that describes your organization’s actions in the event of an oil spill. It does not just function in organizing a fast and effective response to these events; beyond that, it shows the EPA that you have taken serious steps to avoid and mitigate the impact of spills.
While you will have some leeway in crafting this document, the SPCC plan has to include these four core elements:
- Oil spill prevention protocols;
- A list of the people, equipment, and other supplies you have in place for spill prevention;
- Descriptions of your facility’s operations that involve oil; and
- Controls on oil drainage and discharge.
See below for further requirements.
Who Needs An SPCC Plan?
An SPCC Plan must be developed and put into effect by the operator or owner of a facility with the following characteristics:
- Uses, consumes, transfers, or stores oil or oil-based products, such as gasoline, crop oil, adjuvant oil, hydraulic oil, vegetable oil, lube oil, diesel fuel, or animal fat;
- Has reasonable potential for an oil discharge into navigable US waterways (such as rivers and lakes) or adjacent shorelines; and
- Stores in excess of 42,000 gallons of oil in buried containers or 1320 gallons in aboveground containers (including only containers that can store at least 55 gallons).
The SPCC Plan must be kept on file at the facility in a staffed location a minimum of four hours per day.
SPCC Plan Requirements
Here are sixteen critical items to include within your SPCC plan:
- Forecasts for oil discharge
- Inspections of the facility
- Facility description and diagram
- Site drainage
- Secondary diversionary or containment structures
- Facility security
- Staff briefings on avoidance of oil discharge and training parameters
- Necessary characteristics of operating equipment that uses oil
- Procedures for pipes and other transfer equipment
- Integrity testing, overfill, and inspection needs of bulk storage containers
- Brittle fracture assessments of containers that are field contracted and aboveground
- Procedures and stipulations for rack loading and unloading of tank trucks and tank cars
- Approval by management
- Professional engineer (PE) certification (although the facility’s owner or operator can sometimes perform certification – see below)
- Mandatory record-keeping protocols
- Plan review every five years.
SPCC regulations mandate that you provide general details about your facility, including where it is, its operations, ownership information, and how close it is to US waters. Tanks containing oil and oil products should be listed, along with their storage capacity, what is in them, and where they are.
The SPCC plan must describe oil spill prevention methods. Within this section, discuss inspection procedures, training, tank containment, facility security, and locking equipment. Training must occur annually so that your personnel who interact with oil or oil products understand safe operations and the necessary procedures if a spill occurs.
As training requirements indicate, you need to be prepared for the worst-case scenario. The SPCC plan must contain emergency details: the steps that should be taken if a discharge occurs, and up-to-date contact information for anyone who should be contacted.
Finally, SPCC requirements are not “one-size-fits-all” but will be based on an assessment of whether you are a Non-Qualified, Qualified Tier I, or Qualified Tier II facility. Your oil discharge history, storage container volume, and overall aboveground storage capacity will determine which of those classifications applies to your facility.
How Do You Certify Your SPCC Plan? Do You Need A PE?
You may need to get a licensed professional engineer to certify your plan (see below for exceptions). PE certification is a verification of the following five statements by the professional engineer reviewing the SPCC plan:
- The PE or an official agent have inspected the site in person;
- The PE is knowledgeable on full stipulations of the SPCC rule;
- The SPCC plan is suitable to the specifics of the facility;
- Routine examination and testing protocols are included within the document; and
- The document meets the rule’s mandates, complies with established industry standards, and adheres to established engineering best practices.
Exemptions to PE Certification / Ability to Self-certify
Once the operator or owner of a facility has developed the plan, they can certify it themselves if they meet these three qualifications:
- No major spills — There has not been an oil spill of more than 1000 US gallons to navigable waterways or their shorelines in the past 3 years;
- No pattern of minor spills — There have not been two or more discharges of more than 42 gallons of oil in any stretch of 12 months in the last 3 years; and
- Limited aboveground storage — There are no more than 10,000 gallons of oil stored above ground onsite.
An SPCC Plan Crafted with Industry-leading Expertise
Does your facility need an SPCC plan? A written, organized approach to prevention and response is not just about meeting legal requirements. It can also yield an efficient and appropriate emergency response — and prevent spills in the first place — mitigating the potentially massive associated costs.
At AOTC, we tackle complex compliance issues to save you time and money. And with our newest acquisition of L.S. Sims and Associates, a full service environmental consulting and engineering firm located in Rockledge, FL, we now have a professional engineer (PE) on board and available to sign off on your plan. So what are you waiting for? Get compliant today!