SPCC plans: Who needs them?

August 29, 2016

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What is an SPCC Plan?

A Spill Prevention Control and Countermeasures (SPCC) Plan not only ensures regulatory compliance, but also provides your facility with a game plan for preventing and handling releases of regulated materials. Spill prevention is first priority, but accidents do happen. For such events, the plan gives a reference to instruct you in the proper methods of spill response, notification and cleanup.

Some of the precautions and required actions that SPCC plans outline include:

  • Proper examination of active and passive containment for tanks as well as loading/unloading areas, piping and pumps
  • Emergency and spill notification lists with updated contact information
  • Site security checks
  • Integrity testing
  • Monthly/annual inspections
  • Personnel training

Who needs one?

The SPCC rule applies to owners or operators of facilities that drill, produce, gather, store, use, process, refine, transfer, distribute or consume oil and oil products. If you’re not sure if your facility engages in any of these oil-related activities, here are a few questions to answer:

  • Do you store, transfer, use or consume oil or oil products (such as diesel fuel, gasoline, lube oil, hydraulic oil, adjuvant oil, crop oil, vegetable oil or animal fat) at your facility?
  • Do you use oil to heat the building or any equipment at your facility?
  • Could there be a reasonable expectation to discharge oil to navigable waters of the US or adjoining shorelines, such as lakes, rivers and streams?

If you can answer yes to any of these questions, then you probably need an SPCC plan!

If you are operating a facility unrelated to transportation which contains more than 1,320 gallons of aggregate aboveground petroleum storage, and that aggregate is stored in containers with a capacity of 55 gallons or larger, you are required by law to maintain an SPCC plan. If your facility holds 42,000 gallons or more of aggregate petroleum storage completely buried underground and are not regulated by a state-mandated UST program approved by 40 CFR parts 280 or 281, your facility is required by law to maintain an SPCC plan.

What are the benefits of having an SPCC plan—even if my facility isn’t required by law to have one?

  1. SPCC inspections help minimize and prevent product loss due to leaks—saving your facility money.
  2. SPCC plans include a full-site diagram, which is beneficial for a number of other health and safety initiatives and could minimize damages in an emergency.
  3. An up-to-date SPCC plan can save your facility thousands of dollars in fines from the federal or state regulating agencies.
  4. An SPCC plan offers peace of mind and the knowledge that your facility is prepared if an accident were to occur.

 How can my facility acquire a plan?

The specific SPCC plan your facility needs is dependent upon the capacity of oil product storage on your site. If your facility has more than 10,000 gallons of liquid storage capacity, your plan must be prepared and certified by a registered professional engineer (PE).

Facilities with less than 10,000 gallons of liquid oil/fuel storage capacity are not required to hire a registered PE to prepare their plan, and may self-certify.

PPM can assist you in determining if your facility needs to develop an SPCC plan and walk you through the process of plan development should your facility need it. We can also take you through a pre-classification process to determine if your facility is eligible to receive a grant!

 

 Contibuted by Drew Moore and Jared Saterfiel — Monroe, Louisiana