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Written By: Dennis Ruhlin | Mar 23, 2015
Time to Read 11 Minutes
Whether you're in Juneau, Alaska, or Baton Rouge, Louisiana, chances are you have some type of oil or petroleum product at your facility. Depending on what you do, the size of your facility, and the activities you perform there, you might have a little, or you might have a lot. When we visit a site, or talk to personnel on the phone, and learn they have a lot of oil or petroleum, we'll ask if they have an SPCC, or Spill Prevention, Control and Countermeasure Plan, to which we usually hear: What's a SPCC Plan?
I hate to hear it! But, I understand why so many folks are in the dark about SPCC Plans (which I'll explain below). Honestly, I hear it a lot, and from everyone, from new hires to seasoned managers.
So let's shine some light on the subject and get into it.
Let's get one thing clear right now. This is not an SWPPP Plan. That's short for Stormwater Pollution Prevention Plan. They are not the same. They are not interchangeable. Having one does not cover the other. Ok?
SPCC stands for Spill Prevention, Control and Countermeasure. Often times we'll hear "spill plan" or "oil spill plan", or something along those lines. It's ok to call it that if you'd like, but you'll probably end up confusing yourself or your staff.
These plans are required by Federal law under the Oil Pollution Prevention regulations (40 CFR 112 if you're really interested). Briefly, it states that any "non-transportation facility", with the "potential to discharge oil to waters of the U.S.", and who stores oil or petroleum products on-site in excess of 1,320 gallons, needs to prepare and implement a plan meeting the requirements and intent of the regulation.
There're a few key things in there which we need to break down:
To wrap regulations up, just know there is no permit or approval necessary here. You don’t have to give anyone a copy of your plan for any type of review or approval. You simply figure out you need one, get one developed, and start using it.
Usually, it's a notebook-type document, which you'll keep handy at your facility. The ones we prepare usually look like this:
There are 3 types of plans which are dependent on the amount of oil you store, any spill history you have at your site, and the size of your storage containers. They are:
From our experience, any plan which is credible and can even closely conform to the regulations is usually between 15 and 100 pages. A simple, smaller facility will have a smaller plan, and a larger, more complex operation will have a larger plan. Makes sense, right?
Just be warned, and I say this because we've seen it dozens and dozens of times, but anyone who gives you a 1 or 2 page document, and tries to convince you that's your plan and it's all you need, doesn't know what they're doing. If I was you I'd get your money back.
Here's an overview of the plan, and what you'll likely find in it:
It's a lot. Sometimes this information can be summed up quickly, and other times it drags on over the course of 100+ pages. It all depends on your facility, your storage capacity, and your spill history.
When I said "are the tanks contained?", that's because part of the regulations require that tanks be kept inside of secondary containment. A double-walled tank counts, or a concrete vault type tank counts, or a tank sitting inside appropriately sized, waterproof containment all count as secondary containment.
Appropriately sized generally means the storage area holding the tank can accommodate 110% of the tank's contents (although this requirement has changed a bit for technical reasons, and may in some cases require more than 110%). So, if you have a 1,000-gallon tank inside a storage area made of concrete block walls, sitting on a sealed, solid concrete floor, then that storage area usually should be able to hold 1,100-gallons of whatever's in that tank.
As you can see, they can be pretty detailed, very thorough, and comprehensive documents. See why I said 1 or 2 pages doesn't cut it?
You might be thinking, I've never been asked about this, what gives? Well, since this regulation is enforced by the EPA, and you may have never been inspected by them before, you may have never heard of it. We hear this a lot, and it makes a lot of sense.
If no one is enforcing the rules, and the rules aren't clear, then it's understandable that you've never heard of this regulation before. Fortunately, the EPA agrees sometimes, and if you're caught without one, they may go easy on you. However, if you're caught without one and have a spill, you're in for a world of trouble.
What's the real point of this? Given that there's no permit or approval, no government costs involved, and no one will review and approve your plan, the costs are limited only to the costs of SPCC development and any costs associated with improvements or updates needed at your facility. So you can't say this is another "government fee-generator" type thing.
Instead, the real point is to help YOU prevent oil spills at your facility, from accidents, equipment malfunction, vandalism, or more. Given the extremely high costs you'd incur if you did have a spill or discharge at your facility, it seems to be some of the best insurance you could possibly have.
And, at the end of the day, it keeps oil and petroleum away from our nation's waterways. There's no one who can argue with keeping them clear and clean.
And lastly, it helps keep you and your employees safe in an emergency.
Here are some additional resources you may find helpful regarding SPCC information:
Do you need a plan at your facility? If you do, get one ASAP. To learn more, click here to contact us or give us a call at 609-693-8301 to discuss your environmental needs today.
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