SPCC Plan Requirements: Who Needs an SPCC Plan?
- By Cory Levins
- 4 may 2021
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Key Takeaways:- Spill Prevention, Control and Countermeasure (SPCC) plans are required for facilities that store a large amount of oil near waterways.
- The exact contents of an SPCC plan depend on the amount of oil stored and the types of work occurring at the facility.
- SPCC plans must generally include details on the types of spill containment and clean-up measures in place at the facility.
Faculties that Require an SPCC Plan
Pipelines, ships and trucks that move large amounts of fuel between facilities are subject to a separate set of regulations and are not necessarily required to maintain an SPCC. Any facility that moves or stores more than 1,320 gallons of oil aboveground or more than 42,000 gallons underground, and which is potentially at risk of contaminating a waterway with a spill, must create and follow an SPCC plan under U.S. Environmental Protection Agency (EPA) regulations. This includes vegetable oil and other types of oil that are not necessarily used in transportation. Because of the broad range of oils included, airports, farms, fish canneries and even power plants may be required to create an SPCC plan.
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Determining Your Status
When assessing the total amount of oil stored on your premises, you need to include all oil containers 55 gallons and larger. Smaller oil containers do not need to be included in your total. However, large equipment and machinery that contain large amounts of oil for lubrication may need to be included in your assessment. Determining the potential effect of an oil spill requires a detailed look at creeks and streams surrounding your facility. If it is feasible for oil to enter a small stream that then leads to a waterway, you need to create an SPCC plan. Even if you have sufficient man-made barriers in place to prevent a spill from reaching a waterway, you need to create a plan that assumes that these barriers do not exist. Use Safety Cans to Prevent Accidents that Lead to SpillsBasic Requirements for Compliance
Your plan needs to address ways of containing oil spills both while it is stored and while it is being transferred. This may include using spill containment pallets and racks or other drum spill containment equipment, such as trays and sump pumps. This equipment may need to be available at various points around your facility where loading and unloading occur. Large storage areas need to have walls around them to help contain spills, especially if they are outdoors. In some cases, double-walled containers are an acceptable substitute, but they may need to be approved by a Professional Engineer. Keep in mind there may be additional local regulations that are even stricter than federal regulations. Even small containers used for transferring oils, such as safety cans for flammable materials, need to be at least briefly addressed in your SPCC plan, especially if you work with gasoline. Additionally, your plan must include facility diagrams, site security information, personnel training, a 5-Year Plan review and other details to help ensure that both the EPA and your entire team are informed of all risks. Your plan must be approved by a licensed Professional Engineer if your facility has an above-ground capacity larger than 10,000 gallons or if your capacity is less than this and your facility has had spills that were required to be reported to the EPA in the past three years. Even if you have a robust SPCC plan in place, you are still required to report spills to the EPA if they meet certain requirements. This includes all oil spill events where at least 1,000 gallons reach waterways or shorelines in a single spill and events that include two or more separate spills of at least 42 gallons each.
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