Is your facility’s Spill Prevention, Control, and Countermeasure (SPCC) Plan due for review? The SPCC regulations require that SPCC Plans be reviewed at least once every five years, whether or not there have been changes at the facility. Make your next review easier by following these four tips.
Perform Brief Reviews Annually
SPCC Plans must be reviewed at least once every five years, but they are also supposed to be updated when there is a change to the oil storage at a facility. Oftentimes plans aren’t updated when changes are made at the facility, and changes are left to be caught during the next five-year review. Completing a brief review of your SPCC Plan annually can help you keep your plan current, and reduces the burden of catching changes during the five-year review. You’ll also appreciate an up-to-date SPCC Plan when you need to use it during a spill event.
Accurate Data Collection
Inspecting each of your facility’s oil sources is the most time-consuming part of reviewing and updating the SPCC Plan, but it’s also the most important information to accurately collect. Electronic data collection on tablets and smartphones makes the process more efficient and accurate, and it is becoming more common. Mobile apps that tie into GIS programs allow for quick data collection, and they have advanced features like recording locations and geotagging photos of oil sources. Streamlining data collection is especially important if you have a large facility or your oil storage changes frequently. Accurate data collection reduces follow-up and saves you time and money.
Streamline the SPCC Plan
Many SPCC Plans are prepared as regulatory compliance documents, cluttered with tables, text, and figures that aren’t easily reviewed or updated. While the SPCC Plan is a regulatory compliance document at its core, having a smart, simple plan makes it much easier to review and update, while still containing the information required by the SPCC regulations. One way to simplify your SPCC Plan is to use one table that summarizes all of your facility’s oil sources. Avoid duplicating information across multiple tables. You may also consider putting key facility-specific information into one section of the plan text. SPCC regulation requirements that can be met with more boilerplate language can be built into the remaining text portions of the SPCC Plan. It will be much easier to update your SPCC Plan if you only have to update information in one location.
Hang on to Your Documentation
Certain documentation like inspection and testing records must be maintained for at least three years. However, three years may not be long enough if your plan is being reviewed every five years. If your oil storage tanks are large enough, integrity testing by a certified inspector is required every 20 years. Hanging on to that inspection documentation is important because when review time comes, your reviewer will likely be looking to verify when the last integrity testing occurred. Keep records of any site improvements or upgrades to items related to your oil sources, such as grading plans for building expansions, cutsheets for secondary containment structures and oil/water separators, drawings of floor drain routes, and drawings and capacity calculations for oil containment systems. Attaching this documentation to the SPCC Plan as an Appendix is a good way to make sure it is readily available come review time.
4 Tips to Simplify Your Next SPCC Plan Review is Part III of the SCS Engineers SPCC series.
About the Author: Jared Omernik has 12 years of experience helping clients manage and maintain their facilities’ environmental compliance. He has extensive experience preparing SPCC Plans that meet his clients’ needs. Contact Jared or one of SCS’s compliance professionals near you.
Are You Ready to Respond to a Spill? is Part II of the SCS Engineers SPCC series. Click to read Part I here.
Imagine you get a late-night call informing you that a transformer at one of your substations has failed, and as a result, 8,000 gallons of mineral oil spilled. Your next decisions are critical to timely industrial spill response, and taking the right steps will put you on a path to minimizing the environmental impact and your company’s liability. Do you know how you would respond?
If your facility has over 1,320 gallons of oil, your required SPCC Plan should contain spill response steps. If your facility has less than 1,320 gallons of oil, you may not have written spill response steps at all. Whether or not your facilities have SPCC Plans, consider the following tips, so you’re prepared for that late-night call.
Play Where Will a Spill Go?
If a spill occurs at one of your facilities, do you and your employees know where the spill will go? It’s typically easy to track flow paths at facilities in rural settings, but it can still be tricky if the site is pretty flat. Facilities in urban settings can be much more difficult to track. Sure, the spill will go into that storm sewer inlet 100 feet away from the transformer, but where will it go from there?
Critical hours can be lost during a spill because the response team is pulling manhole lids to determine the path of the spill. A little time spent upfront to determine where a spill would go can save a lot of time and headaches.
So take a peek down that inlet grate to see where the pipe goes. Or give a call to the local municipality. Many have GIS databases mapping the storm sewer system, and they can help determine the correct flow path that a spill would take. Knowing where to deploy your spill response materials is a critical step to spill response.
Conduct a Mock Spill Drill
Try conducting a mock spill drill, so your employees understand your spill response procedures, where you keep spill response materials, and how to deploy those materials. Running through these items on a PowerPoint slide is a good start, but you can’t beat the hands-on activity of actually opening up the spill kit and laying down some boom. A spill drill can also help you identify potential issues with your planned response techniques.
Review Your Spill Kits
Spills kits, especially those stored in maintenance shops, are prone to dwindling inventories over time. While raiding the spill kit to wipe up a few drops of oil isn’t a bad idea, it is important to replenish the spill response materials for an emergency. Make sure your spill kits are stocked by keeping an inventory list taped to the top of the spill kit or just inside the lid. Check the spill kit against the inventory list regularly and replenish missing items. Each spill kit should include personal protective equipment (PPE) appropriate for handling the types and amount of chemicals that the kit is expected to control. PPE should be in good working order. Replace any PPE that is expired or showing wear.
It is also important to understand that absorbent materials come in many styles and work in different ways. Teach your oil-handling employees when to use granular absorbent, or pads and mats, and the proper way to lay booms and socks to prevent spills from seeping through the cracks. If you use “oil-only” absorbents, help employees understand the situations in which these are preferable over a universal absorbent.
Know When You Need to Call for Help
Do you know when you will call for outside spill response assistance versus what your staff can handle internally? The answer can vary by facility type, spill scenario, the experience level of your staff, and spill response materials and equipment that you have available. It’s important to think through different scenarios and know your internal capabilities and limitations, and when you need to call a spill response contractor.
Do you know who you will call? And do you have an agreed-upon response time established with the contractor? Depending on your facility’s location, it could take hours for a spill response contractor to reach the site. Knowing that lag time will help you plan for steps that your internal resources can take until the spill response contractor arrives.
Don’t let spill preparedness slip down your to-do list again. Use these techniques, so you are ready when the next spill occurs.
Jared Omernik has 12 years of experience helping electric utility companies with environmental compliance. Jared has extensive experience helping companies with SPCC compliance and SPCC Plan preparation. For questions about the SPCC Rule or spill response or preparedness, contact Jared at or find the nearest Environmental Engineers on our website.
Do you know how much oil you store in aboveground containers at your facilities? If you have more than 1,320 gallons at a facility, you may need an SPCC Plan. SPCC stands for Spill Prevention, Control and Countermeasure, and it is a federal rule (40 CFR 112 in the Federal Register) designed to prevent oil-based products from entering navigable waterways of the United States. But it’s about more than just compliance. It’s an important tool to help you limit your liability.
As a utility leader, your focus is to deliver electricity to your customers; however, facilities covered under the SPCC Rule are subject to inspections and potential enforcement actions if your practices are out of compliance.
The 1,320-gallon threshold isn’t the only requirement for an SPCC Plan. The SPCC Rule only counts oil storage containers with a capacity of 55 gallons or more. Many electric utility facilities will meet the oil storage threshold, including substations, storage yards, power plants, and operations and maintenance facilities.
Another criterion is that a facility must reasonably be expected to discharge oil into navigable waters or adjoining shorelines of the U.S. The Environmental Protection Agency (USEPA) does not define what “reasonably be expected” means. Instead, the responsibility is on the facility owner or operator to determine the potential for discharge. In reality, it’s usually easy to think of a scenario where spilled oil could reach a waterway. Even if you think a spill would never reach the stream, what if there was a significant rain event that washed away spilled oil on the ground through a storm sewer? Often “reasonably be expected” is not challenged, and it’s best to err on the side of caution.
It’s time to prepare an SPCC Plan. The Plan summarizes your facility’s oil sources, identifies spill response coordinators, and outlines your spill prevention measures and spill response procedures. There are three options: 1) Prepare the Plan yourself; 2) Use a third-party provider to prepare your Plan; or 3) Have a licensed professional engineer (PE) prepare your Plan. The option you choose depends on how much oil you store at your facility and your working knowledge of the SPCC Rule.
If your facility has less than 10,000 gallons of oil and no single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you may prepare your own SPCC Plan, following the USEPA’s Tier I qualified facility template.
You can download the USEPA’s Tier I qualified facility template here: https://www.epa.gov/sites/production/files/2014-05/documents/tier1template.pdf. It is the cheapest way to comply with the SPCC Rule. You need to be familiar with the SPCC Rule’s requirements to complete a self-certified plan. You must also follow all of the requirements without deviation.
If your facility has less than 10,000 gallons of oil and a single aboveground oil storage container with a capacity greater than 5,000 U.S. gallons, you qualify under the USEPA’s Tier II qualified facility category. The USEPA does not provide a plan template for a Tier II qualified facility. You can still prepare the Plan yourself, or you may hire a third party or PE to prepare the Plan for you. If you prepare the Plan yourself, you must still follow all of the requirements precisely without deviating from them.
If your facility has greater than 10,000 gallons of oil storage, you must have a licensed PE prepare and certify your facility’s SPCC Plan. The Rule allows PEs the flexibility to deviate from certain requirements, so you may decide you want a PE to prepare and certify your plan for your Tier I or Tier II qualified facility.
An SPCC Plan is about more than just compliance. An SPCC Plan contains important information that will be critical if you have an oil spill. The Plan contains inspection forms and protocols that help you maintain your oil sources and prevent a spill from happening in the first place. It identifies the single point of contact, an “SPCC Coordinator” for the facility. If there is a spill, the Plan contains steps to contain and control the spill initially, and the proper contacts to notify internally and externally.
The SPCC Rule requires oil-handling personnel to receive annual training to respond to spills in their work areas properly, and the SPCC Plan contains the material that must be covered in training. The SPCC Plan also contains forms for you to document training, plan reviews and updates, and spill notifications.
Work with your staff to determine if the SPCC Rule applies to you. An SPCC Plan is a required document for certain facilities to help you comply with the SPCC Rule and gain the benefits of having a plan in place. But more than that, it’s a practical document designed to assist with training and inspections while serving the function to help prevent spills from occurring. And if spills do occur, an SPCC Plan provides the guidance to help control the spill and limit your liability.
Read Part II – Are You Ready to Respond to an Industrial Spill?
About the Author: Jared Omernik has 12 years of experience helping electric utilities comply with environmental regulations, including helping utility owners and operators build and review SPCC Plans and Storm Water Pollution Prevention Plans (SWPPPs).
Secondary containment is a basic engineering control to prevent a chemical or oil spill. There are misconceptions, though, regarding secondary containment requirements. In terms of oil-based storage, these misconceptions can lead to not enough containment capacity, significantly more containment capacity than necessary, or simply not providing the right level of containment when containers are grouped.
Chris Jimieson of SCS Engineers explains the five most common misperceptions and advises you how to keep your facility in compliance.