SPCC Plans

July 13, 2020

industrial spill response

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.





Posted by Diane Samuels at 6:00 am

January 9, 2019

If you use hazardous substances or store oils or fuels on-site at your facility, you need to be prepared to respond appropriately to a release. Having a written plan is your company’s first step to protecting human health, the environment, and your company’s assets from the aftermath of a spill.

Not all of your employees are qualified to clean up all releases. Training may be required if there are potential risks. Choosing the correct level of training and the right people to train is essential to maximizing your facility’s spill preparedness. Read more about spill response teams here.

Spill planning and reporting can be subject to rules from multiple agencies, depending on what spilled, where the spill happened, and whether it leaves your property.

Which Plan Does My Facility Need?

  • Resource Conservation and Recovery Act (RCRA) Contingency Plan
  • Facility Emergency Response Plan
  • Spill Prevention Control and Countermeasure (SPCC) Plan

 Where do I Start?

You can start by assessing your facility’s spill potential. Take an inventory of the chemical products at your facility. You will want to include some details in your assessment such as the related hazards of each product, the amount you store on-site, the biggest container, and where these are stored and used in relation to employee workstations and other operations at the facility. This assessment may already be incorporated into your written plans.

Ask yourself these questions:

  1. Are emergency responders able to get to our site quickly? These entities could include the local fire department, community hazardous materials team, or a private spill cleanup contractor.
  2. Does our facility have a written plan that provides for facility personnel responding to spills?
  3. Do we want employees to be able to take defensive actions to help stop a release from spreading?
  4. Do we want employees to be able to take offensive action to stop the release at the source?

Based on your answers, choose the level of spill response training that best suits your needs…continue by reading Cheryl Moran’s article on spill response training.

Posted by Diane Samuels at 6:09 am