Does Your MSW Facility Need Oil Spill Prevention Planning? It Might!

May 22, 2023

Oil Spill Prevention

Municipal Solid Waste Facilities (MSWFs) are subject to a wide range of federal, state, and local regulations that govern their operations. Regulatory compliance is essential to ensure the facility operates safely, protects the environment, and meets its legal obligations. The regulatory priorities for a solid waste facility can vary depending on the specific facility and its location. Waste management, air quality permitting, leachate management, and landfill gas management are top regulatory priorities for most solid waste facilities. It is equally important for facility owners and operators to plan for oil spill prevention, but this can be a blind spot. The Federal Spill Prevention, Control, and Countermeasure Rule (SPCC) primarily governs oil spill prevention planning.

What is the SPCC rule?

The Federal Spill Prevention, Control, and Countermeasure Rule (SPCC) (40 CFR 112.1-112.12) applies to solid waste landfills and transfer stations. The U.S. Environmental Protection Agency (USEPA) requires an SPCC Plan for any non-transportation-related facility with an aboveground storage capacity of 1,320 gallons or more and if it could potentially discharge oil to navigable waters or adjoining shorelines. The SPCC rule aims to prevent oil spills and limit significant environmental and economic impacts.

Basic SPCC Requirements for MSWFs

The SPCC regulations require solid waste facilities to implement spill prevention measures to reduce the likelihood of spills, including providing adequate secondary containment systems for all oil storage containers and spill prevention controls such as automatic shut-off valves or overfill prevention devices.

The regulation also requires an SPCC Plan that includes emergency response procedures in the event of a spill and contact information for assigned emergency personnel. Facilities must document annual and ongoing SPCC training for all personnel who handle petroleum products.

Facilities must regularly inspect their oil storage containers and secondary containment systems to ensure they are in good condition and leak-free. Each facility must maintain inspection records for potential EPA review.

SPCC Plans must be updated and re-certified by a professional engineer (PE) every five years. Additionally, amendments to SPCC Plans must be PE certified within six months of any change in the facility design, construction, operation, or maintenance materially affecting the facility’s oil spill potential.

Petroleum Product Storage at MSWFs

MSWFs use a variety of petroleum products for their ongoing operations. Here are some examples:

1. Fleet Fueling – Many MSWFs maintain on-site diesel or gasoline storage tanks to fuel their fleet vehicles. These aboveground storage tanks and associated secondary containment, piping, valves, and product transfer areas (dispensers or loading racks) are subject to the SPCC rule. In some instances, underground storage tank systems are also subject to the SPCC rule.

2. Equipment Maintenance – Facility equipment requires regular maintenance if using petroleum products subject to compliant storage and handling procedures. Some examples include engine oil changes (new motor oil), equipment lubrication (gear oil), or hydraulic system maintenance (hydraulic oil). Any aboveground storage tank, drum, or portable tote tank with a 55-gallon or greater capacity counts toward the aggregate SPCC threshold of 1,320 gallons.

3. Generators – MSWFs may use generators to power their operations during power outages or other emergencies. Large diesel generator sets with integrated storage tanks typically have 100 gallons or greater capacities.

4. Used Oil – At the MSWF, used oil might originate from vehicle engines, industrial gearboxes and pumps, compressors, and hydraulic units. Some facilities maintain used oil storage tanks for oil burners that heat facility buildings.

5. Heating Oil – MSWFs may maintain No. 2 fuel oil tanks for office, warehouse, shop, or other building heat.

6. Transformers – Transformer oil is also subject to the SPCC rule when transformer storage capacities are 55 gallons or greater.

Risk Management and Operations

Solid waste facilities and landfills are responsible for preventing environmental impacts and complying with regulations. Implementing an effective SPCC program can help to prevent petroleum leaks and spills from entering natural waterways. In addition to the Federal SPCC requirements, some States have more stringent oil spill planning requirements, so facility owners need to seek guidance when developing their oil spill prevention program. With the proper risk management measures, solid waste facilities and landfills can do their part in protecting the environment while maintaining their essential operating budget.

SCS has prepared and updated thousands of SPCC Plans for clients across the U.S. and in various industries, including MSWFs, bulk petroleum storage terminals, chemical storage facilities, and animal fat and vegetable oil storage facilities.

Find out more about SPCC Planning and Spill Prevention

Meet our Author, Michael Morawski, Project Manager