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.
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.
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.
MSWFs use a variety of petroleum products for their ongoing operations. Here are some examples:
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
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 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’s 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.
About the Author: Jared Omernik has years of experience helping clients manage and maintain their facilities’ environmental compliance. Contact one of our professionals with extensive experience preparing SPCC Plans (below), or use SCS’s Find Our People search to find staff nearby.
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.
