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.