SPCC Plan?? What's an SPCC Plan?
Most concrete, mining and other industrial facilities may very well be required to prepare and implement an SPCC plan. Asphalt plants almost always do. SPCC plans, or Spill Prevention, Control, and Countermeasure plans are required by federal law for any facility that has over 1,320 gallons of any type of oil in any size container down to and including 55 gallon drums. But what exactly IS an SPCC plan?
An SPCC plan is somewhat like an emergency contingency plan, designed to identify potential oil spill risks, potential discharge scenarios, and measures implemented to ensure that oil spills don't occur, and if they do, that they are handled correctly.
What's an SPCC plan look like?
It usually is a "notebook" style plan, much like a SWPPP stormwater plan, which it is commonly confused with. For most facilities, an SPCC plan ought to be about 20-60 pages to do justice to what is required. A plan of a few pages probably is inadequate, and one that is in the hundreds of pages is probably overkill (unless you're a very complex facility containing a lot of oil).
Your SPCC plan should be reviewed and updated on a regular basis, particularly when there are changes involving oil handling or storage at your plant, or the amount of oil stored there changes.
Changes to the SPCC requirements recently have made it a bit easier to prepare these plans, particularly for smaller facilities not storing a lot of oil (generally for those between 1,320 and 10,000 gallons). In many cases, facilities can prepare their own plans using USEPA templates and won't require certification by a professional engineer.
An SPCC plan requires several things from a facility, including (but not limited to):
- A thorough evaluation of all oils stored at the facility, and the likelihood of them spilling.
- Practices to ensure that the chance of oil spills is minimized, including secondary containment for all oil containers, presence of spill cleanup and control materials, and adequate security.
- Regular documented inspections of all oil containers and their piping, usually required monthly.
- SPCC Training, at least annually, for all employees involved in oil handling.
Unlike most environmental regulatory programs, no "permit" or registration is needed if you need an SPCC plan. You simply must prepare and implement one. Furthermore, most states in the US do not administer the SPCC program, leaving it instead up to the USEPA.
Failing to have an SPCC plan when one is needed can have big consequences, both in terms of having an oil spill, and in facing serious enforcement from the USEPA. Don't let this happen to you - if you need an SPCC plan, get one!