Spill Prevention and Countermeasures

A written plan is required under the Spill Prevention, Control and Countermeasures (SPCC) regulations if you have a non-transportation related facility with an aboveground (non-buried) oil storage capacity greater than 1,320 gallons (or greater than 660 gallons aboveground in a single tank) or a buried underground oil storage capacity greater than 42,000 gallons.

A SPCC written plan is a document of your facility’s:

• Design, operation and maintenance procedures to prevent and control spills or discharges of oil into the navigable waters of the US
• Procedures on how facility personnel are to respond effectively to a discharge

What types of oil does the rule address?
The term oil means oil of any kind or in any form, including, but not limited to: petroleum, fuel oil, sludge, oil effuse, oil mixed with wastes other than dredged spoil, fats, oils or greases of animal, fish, or marine mammal origin, vegetable oils, including oil from seeds, nuts, fruits, or kernels, and other oils and greases, including synthetic oils and mineral oils.

This determination is based solely upon a consideration of the geographical and location aspects of the facility. The location of the facility must be considered in relation to streams, ponds and ditches (perennial or intermittent), storm or sanitary sewers, wetlands, mudflats, sandflats, or other navigable waters. The distance to navigable waters, volume of material stored, worse case weather conditions, drainage patterns, land contours, soil conditions, etc., must also be taken into account.

In addition, according to the rule, this determination may NOT include consideration of man-made features such as dike, equipment or other structures which may serve to restrain, hinder, contain or prevent an oil discharge.

What do I have to do now? Although each SPCC Plan is unique to the facility, there are certain elements that must be included in order for the SPCC Plan to comply with the provisions of 40 CFR 112. Three areas which should be addressed in the Plan are: 1) operating procedures the facility implements to prevent oil spills: 2) control measures installed to prevent oil from entering navigable waters or adjoining shorelines; and 3) countermeasures to contain, cleanup, and mitigate the effects of an oil spill that has an impact on navigable waters or adjoining shorelines. Some other important elements of an SPCC Plan include, but are not limited to, the following:

• Professional Engineer certification
• Plan must follow the sequence of 40 CFR 112.7 or provide cross-references to the requirements in 40 CFR 112.7
• Facility diagram
• Oil spill predictions
• Facility drainage
• Facility inspections
• Site security
• Management approval
• Appropriate secondary containment or diversionary structures
• Loading/unloading requirements and procedures for tank car and tank trucks
• Personnel training and oil discharge prevention briefings
• Brittle fracture evaluations
• Bulk storage container compliance
• Transfer procedures and equipment (including piping)

Please contact us for more information on Spill Prevention and Countermeasures.