Learn how SPCC Plans apply to those in the marine industry.
When it comes to operating any industry on the water, be it a port, local marina, yacht basins, boat maintenance facilities, you name it, you often face unique considerations simply due to the proximity to water, including SPCC Plans. After all, many of the environmental regulations in the US are aimed at improving water quality, so for someone on the water, staying ahead of regulations can be challenging.
SPCC Plans and how they apply to those in the marine industry are no exception. With a history of fairly poor enforcement efforts, this Federal level regulation often catches marinas and others in the marine industry off-guard. Whether you're trying to stay ahead of the curve or found out the hard way that your facility needs an SPCC Plan, let's dive in and discuss some details about SPCC Plans and the marine industry.
Does a marina or a marine-industry related facility need an SPCC Plan?
The short answer (assuming you meet the oil storage and/or some other criteria) is YES.
Regardless of your industry, if your facility has over 1,320-gallons of oil aboveground in containers larger than and including 55-gallon drums, then yes, you need an SPCC Plan. The same goes if you have 42,000-gallons underground, but from our experience, that's much rarer for marine-related facilities.
There is no way to get around it - the criteria are plain and simple. If you store oil at or above those thresholds, then yes, you need an SPCC Plan.
If this subject is completely new to you, check out two of our intro articles on the subject to learn more about some SPCC Plan basics.
The short answer is - it's the law. SPCC regulations have been around for decades at this point, and as with anything else, ignorance of the law is not an excuse.
The bigger reason is that your facility has the very real possibility of accidentally releasing oil into a waterbody, which as you can guess, is a bad thing for everyone! Consider the difference between a facility located miles inland using oils and petroleum products. While they still need SPCC Plans, the chance of an oil leak entering a waterbody is much lower than it is for anyone within the marine industry. Since your facility operates on the water, oils, fuels, lubricants, etc., need to be carefully handled, stored, and treated simply due to the proximity to the water.
That's where an SPCC Plan comes in.
What kind of "oils" at a marina are subject to SPCC Plan regulations?
SPCC regulations cover virtually any type of oil product - gas, diesel, lubricants, motor oil, hydraulic oil in lifts, greases, synthetic oil, etc. In short, any kind of oil or petroleum product at a marina could be covered under SPCC regulations.
Generally, this means two areas at a marina or a marine-related facility - fuel tanks and maintenance-related areas such as garages and workshops.
While it's easy to identify and focus on large fueling tanks, it's pretty common for other areas of the facility to be (incorrectly) ignored. Have a drum of motor oil in a garage? It needs to be included. Have a mobile tank you tote around the facility that's used to fuel boats or equipment? That's included as well.
What kind of requirements does a marina have with regard to SPCC Plans?
A facility within the marine industry needs to follow the same SPCC requirements as any other industry, which basically are:
While that may sound like a lot, honestly SPCC Plans are some of the easiest environmental regulations to stay in compliance with. For additional information on the subject, check out the following articles:
Additionally, one of the biggest requirements of an SPCC Plan is that aboveground storage tanks are kept within secondary containment. This means oil-storage tanks at a marina must be either double-walled ASTs or stored within some type of confined area, such as a concrete-lined & walled area capable of containing the entirety of the oil tank, plus room for precipitation. On occasion, active containment measures (such as spill kits, floating booms, etc.) may be considered secondary containment, but from our experience regulators don't love to see this and this can often cause issues with inspections from government agencies.
Who inspects SPCC Plans at a marina?
For most marine industry facilities, SPCC inspections will solely be handled by members of the USEPA. Having said that, it's not uncommon for local agencies, ranging from state environmental departments to local fire departments, to ask about your SPCC Plan. It all depends. To learn more, check out Who enforces SPCC Plans?
Do I need a professional engineer-certified SPCC Plan at a marina?
There is no default yes or no answer. Instead, it depends on the following:
If you have over 10,000-gallons of oil and/or petroleum products in aboveground storage tanks, you'll need a PE Certified SPCC Plan.
If you've had a release of oil to a waterbody or adjoining shoreline 3-years prior to developing the SPCC Plan, you'll need a PE Certified Plan. There are some technicalities here, but as a general rule if you've had a release, talk to an expert before you get an SPCC Plan.
If you live in a state where the state-level PE licensing board says you can't prepare your own SPCC Plan, then you'll need to hire an expert. A word of advice from experience - figuring this out is easier said than done.
Are SPCC Plans unique to a marina or marine-industry facility?
Yes. SPCC Plans are always unique and need to be developed specifically to each individual location. If you're responsible for two marinas, each marina would have an individual, unique SPCC Plan. You can't copy-paste and use the same SPCC Plan at every facility you have.
How much does an SPCC Plan cost a marina?
Regardless of how you fall into the marine industry, whether you're a local mom & pop marina, a larger national level marina chain, build boats, maintain them, you're the manager of a port or ferry terminal, you name it, the cost to develop an SPCC Plan is going to depend.
Having said that, an SPCC Plan for a marine industry-related facility is generally going to cost between $1,500 and $4,500. Anything cheaper and you're likely buying a piece of junk, and probably better off using the USEPA's free Tier I SPCC Template. More expensive than $4,500 and you start to get into the large, complicated facility territory.
How long does it take to get an SPCC Plan at a marina?
Generally speaking, an SPCC Plan can be put together fairly quickly. Since these plans aren't submitted to or reviewed by any government agency, once they're made, they're ready to go!
So, the time it takes to put together an SPCC Plan at a marina is going to depend on two things:
If you're doing it yourself, you may have to factor in a learning curve to either use the free EPA template or develop a compliant plan on your own. For some, this is a piece of cake. For others, this is an impossible task, which leads to...
If you're hiring an environmental professional to develop an SPCC Plan for your marina, then however long they take to put the plan together is how long it takes to get your SPCC Plan. If you hire someone and they say it'll take 60 days from start to finish, then that's your answer. Conversely, if you're in a jam and need an SPCC Plan pronto, then you can expect your plan much, much quicker. It all depends on scheduling, availability, project queues, your needs, etc.
Getting an SPCC Plan developed at your marina or other marine-related facility isn't easy, but it doesn't have to be challenging. If you find yourself needing help getting your facility into compliance with SPCC Plans, need help updating or revising and old document, or just need a hand with training, we'd love to talk.
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