Are you looking for information about a Spill Prevention and Control Countermeasure Plan (SPCC) and whether your company needs one? Consider this guide to help you make an informed decision.
The formal name for these plans is spill prevention, control, and countermeasure (SPCC) plans. They are intended to help guard against oil spills into navigable waters or onto shorelines. The plans have three components, which include:
Ideally, such a plan will help businesses avoid a spill altogether. However, the plan also lays out control and countermeasure steps should a spill occur.
Who Needs a Spill Prevention and Control Plan?
Not all facilities that store oil are required to have an SPCC. The EPA federal agency laid out specific criteria regarding the types of companies that must adopt a plan. A facility falls under the purview of the rule if it:
- Stores 1,320 gallons or more of oil products in above-ground containers or
- Stores 42,000 gallons or more of oil products in buried containers.
Additionally, there must be a “reasonable expectation” of an oil discharge into navigable waters. If a facility meets one of the storage thresholds and is in proximity to navigable waters, it needs an SPCC plan.
The rule is not limited to facilities storing petroleum products. Many different oil-based products are also covered. A few examples include:
- Fuel oil
- Oil refuse
- Oil mixed with waste
- Greases from animals
- Vegetable oils
- Mineral oils
- Synthetic oils
Some of the facilities or equipment that may fall under the scope of this rule include:
- Tanker trucks
- Transfer hoses
- Railroad cars
- Waste treatment facilities
- Oil storage facilities
- Oil production facilities
Again, it is important to read the specific provisions and exceptions laid out in the rule to determine whether your facility must develop an SPCC plan.
Essential Elements of an SPCC
The EPA has created a standard SPCC template. This template is one of your best resources for ensuring environmental compliance. If your company is required to create an SPCC plan, you will need to implement a few control measures to support compliance.
First, you must routinely check for storage tank issues. These include staining and leaks. If any issues are detected, you must document what actions you took to remedy the problem.
You also need a spill kit on-site. The size of the spill kit will vary depending on how much oil you store. The kit should include items such as:
- Wet mops
- Personal protective equipment
- First aid equipment
- Absorbent materials
- Plugs to stop leaks
- Drain protectors
Your plan should outline how you intend to use the above items to mitigate environmental harm. It should also include preventive measures that your company is taking to prevent spills altogether.
Using an SPCC Checklist
The SPCC checklist can be a great proactive spill prevention tool when used appropriately. Your company should perform checks of storage equipment at regular intervals. The findings of these checks can be documented on your checklist. Some of the concerns that you should look for include:
- Tank deterioration
Any concerns must be documented on the SPCC checklist. The most important deficiencies to document are spills and leaks. You must list how many leaks have occurred in a specified time period (usually three years), and you are also required to list what volume of oil leaked out during the incident.
Filling out an SPCC checklist is a straightforward process. However, it can also be quite time-consuming due to the length of the standard SPCC checklist document.
The average checklist ranges from 20 to 26 pages or more. Many companies seek the assistance of outside compliance experts when creating their spill prevention and control plan or completing their SPCC checklist.
Learn More from RSB Environmental
As you can see, a spill prevention and control plan is critical for compliance. However, simply having an SPCC will not ensure total compliance. Your organization must also adhere to a multitude of other environmental regulations. If you want to learn more about SPCC and other regulations, RSB Environmental can help.
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