SPILL PREVENTION

A Spill Prevention Control and Countermeasure (SPCC) plan is a document that the United States Environmental Protection Agency (USEPA) requires industrial facilities with over 1,320 gallons of aggregate oil storage capacity to implement. The USEPA defines oil as “…including, but not limited to: petroleum; fuel oil; sludge; oil refuse; 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.” The most common regulated oils VET’s clients store include gasoline, diesel, and motor oil. An SPCC plan is site-specific and establishes procedures, methods, equipment, and inspection protocols to help prevent oil and petroleum product discharge from a facility and to promote appropriate response to spills. The goal of an SPCC plan is to reduce the amount of oil and petroleum products discharged to the environment to protect navigable waters, shorelines, and land-based resources in the United States. VET will develop a site-specific SPCC plan for your facility that includes required spill prevention countermeasures, spill response, training, and recordkeeping to keep your facility compliant. Click here for an overview from the United States Environmental Protection Agency on SPCC regulations.

SPCC plans must be reviewed and re-certified every five years to comply with 40 CFR §112. More frequent re-certifications may be warranted if your facility has a change in key facility personnel, increases its oil capacity, develops new spill prevention countermeasures, or if the plan requires any other technical amendments. VET recommends that each facility review their SPCC plan annually. Technical amendments, including changes to oil storage containers, piping, or secondary containment structures, must be certified by a Professional Engineer (PE).

The SPCC requirement is a part of the Oil Pollution Prevention regulation set forth by the Clean Water Act in 1973. The Oil Pollution Prevention regulation requires facilities to develop plans that detail both oil storage and spill response procedures. SPCCs are self-implemented plans. This means there is no formal permitting process associated with the regulation. However, local, state, and federal regulatory agencies may ask to inspect your SPCC plan during a facility inspection if you are required to maintain a plan. Therefore, if your facility is regulated and you do not have a current plan on file, you are subject to violations. Records of inspections and trainings outlined in your site-specific SPCC plan must also be kept on-site with your SPCC plan. Click here for details on the legislation from the United States Environmental Protection Agency that established the SPCC.

Facilities maintaining at least 1,320 gallons of aboveground aggregate storage capacity or 42,000 gallons of underground aggregate storage capacity are required to have an SPCC plan in place. If you are unsure if you operate a regulated facility, VET recommends conducting a fluids storage inventory at your facility. To conduct a fluids storage inventory, walk your entire facility and note the volume of all containers with greater than or equal to 55-gallon capacity storing oil or petroleum products. Additionally, make sure to include empty containers in your inventory – they are regulated and count toward your facility’s storage capacity! Oil-filled operational equipment (OFOE) at your facility must also be included in your fluids storage inventory. Once you have completed your site walk, find the total volume of all containers combined. If you have more than 1,320 gallons, you will need an SPCC plan! VET will also visit your facility upon request and conduct a fluids storage inventory. Click here for help in deciding in the SPCC rule applies to your facility.

This depends on your state’s requirements, facility’s aggregate storage capacity and whether your facility has had previous discharges of oil. Facilities with under 10,000 gallons aggregate storage capacity are able to self-certify their plans if, within three years of operation, the facility has not had a single discharge of oil exceeding 1,000 gallons or two discharges of oil each exceeding 42 gallons within 12-month period. This means they are not required to employ a Professional Engineer (PE) to develop and certify an SPCC. However, facilities that have over 10,000 gallons of aggregate capacity, must employ a PE licensed in their state to certify the SPCC plan. Some states do not allow facilities to self-certify SPCC plans, no matter the facility’s aggregate storage capacity. VET recommends consulting with a PE prior to developing an SPCC, even if you are able to self-certify to ensure your plan is complete and accurate. Many of our clients prefer to employ VET to develop their SPCC plan even if they have less than 1,320 gallons of aggregate storage capacity. Commissioning a plan from a competent and certified professional ensures it is done right providing you with peace of mind. Click here for the qualifiers for an SPCC Rule outlined by the United States Environmental Protection Agency

SPCC plans require routine inspections to ensure all storage methods and equipment are effective in preventing spills at your facility. SPCC plans require an annual comprehensive inspection along with monthly inspections. VET provides all necessary inspection checklists with your SPCC plan. VET has formatted the checklists as a series of yes or no questions, so you know exactly what you need to do. Our inspections are designed to be user friendly so the owner/operator may delegate the task of inspection completion to those most familiar with and most involved in day-to-day operations at the facility. When in doubt, give us a call! Click here for a bulk storage container fact checklist from the United States Environmental Protection Agency.

Keeping up with your inspections is the first key to preventing spills. Fluid storage containers including tanks, drums, and IBC totes should be inspected regularly for rust, dents, holes, and cracks. Ensure you replace or maintain fluids containers as they show signs of wear and tear. This ensures that all tanks at your facility are sound and will safely contain fluids. Cracks, dents, and rust all compromise the integrity of the tank, increasing the likelihood of leaks and spills. Additionally, single-walled fluids containers should be stored inside a secondary containment unit such as a pit or concrete containment vault. This way, if a spill does occur, the secondary containment unit will catch the spill and prevent fluids from impacting your facility or, even worse, migrating away from your facility. Click here for details from the United States Environmental Protection Agency on SPCC inspections.

Yes! Secondary containment should hold 110% of the volume of the largest fluid container in the secondary containment unit. Let’s look at an example. If you have a 400-gallon steel tank, three 55-gallon drums, and a 500-gallon steel tank all located within one secondary containment unit, what would your secondary containment volume need to be? The answer is 550 gallons (500 gallons x 1.10 = 550 gallons). This ensures that if your largest tank starts leaking, your secondary containment unit can store the full volume of the largest container, while providing overage to account for other spills or introduction of storm water. OFOE may also be subject to secondary containment requirements. It is best to consult with a Professional Engineer (PE) to ensure your chosen secondary containment unit is adequately sized for your specific oil storage scenario. Click here for the United States Environmental Protection Agency’s specifications for secondary containment.

Yes, VET recommends maintaining spill kits in areas where spills and leaks are most likely to occur. Typically, this means you should maintain an oil spill kit in the areas of your facility where oils are stored. For example, at an automotive recycling facility, VET recommends maintaining fully-stocked spill kits in the engine and transmission storage area, large core storage area, fluids storage area, parts storage area, and dismantling area. This ensures that employees are readily equipped to cleanup spills on occurrence. Spill kits should, at a minimum, be stocked with absorbent materials such as pads and booms, safety gloves and other necessary personal protective equipment (PPE), and disposal bags. Spill response supplies should be inventoried at the time of your SPCC plan preparation, and all facility personnel should be trained on how to use them, and where they are kept. Click here for a reference sheet outlined by the Indiana Department of Environmental Management for more information for an emergency response to a spill

The first thing you should do is notify key facility personnel, such as the on-duty manager. While someone is notifying the applicable on-site personnel, the spill should be contained as much as possible using your facility’s spill supplies. Containment booms are particularly useful to immediately contain a spill. If the spill is less than 25 gallons and the facility can easily contain it, you should clean up the spill. Be sure to maintain all disposal documentation including notes regarding the spill clean-up procedure, disposal documentation, and associated photos on file.

If the spill has the potential to reach navigable waters or presents immediate danger to human health, immediately identify emergency offices. This includes your state regulatory agency, local police, local fire department, and the National Response Center (NRC). VET provides a Spill Response Immediate Actions flow chart with all SPCC plans. This flow chart details actions that should be taken in response to a spill such as what agencies to notify and when to submit a written report. VET also provides a list of emergency contact information for the applicable state agencies, local departments, cleanup contractors near your facility, and key facility personnel. Together, these two items provide straightforward information on the notification and spill reporting processes.

Click here for the oil discharge reporting requirements provided by the United States Environmental Protection Agency.