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.
The Department of Toxic Substances Control (DTSC), State Water Resources Control Board, and San Francisco Bay Regional Water Quality Control Board have developed supplemental vapor intrusion guidance for conducting vapor intrusion evaluations in California. The Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion is available for review and public comment until 12:00 noon, April 30, 2020. Click here for available public meetings and comments.
According to the published Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion Executive Summary
Background
Toxic vapors can move from contaminated groundwater and soil to indoor air. This process is called vapor intrusion. Vapors inside buildings can threaten human health. The science behind vapor intrusion has been evolving quickly. To protect the health of Californians, the DTSC and the California Water Boards drafted a supplement to the existing vapor intrusion guidance. This is important information to collect for environmental protection. This document is called the “Draft Supplemental Guidance: Screening and Evaluating Vapor Intrusion” (Draft Guidance). This Draft Guidance contains recommended improvements for vapor intrusion investigations and promotes consistency throughout the state. It also offers suggestions on the following topics:
The Draft Guidance is intended to be used with existing State guidance – DTSC 2011 Vapor Intrusion Guidance and San Francisco Bay Regional Water Board 2014 Interim Framework 1 – when there is a spill or disposal of vapor-forming chemicals. This guidance does not apply to any leaking petroleum underground storage tanks (USTs) since they are governed under the State Water Resources Control Board’s Low-Threat UST Case Closure Policy.
Four Steps to Evaluate Vapor Intrusion
The Draft Guidance describes four recommended steps to decide if there is vapor intrusion that could pose a risk to the health of people inside buildings. These actions are meant to protect public health and should be carried out under the oversight of the lead regulatory agency.
Step 1 – Decide which buildings should be tested first and how.
When there are several buildings, start with those that are occupied and closest to the contamination. If a building is directly above or very close to the spill, or if it is likely that the sewer could bring toxic vapors inside, skip Step 2 and go directly to Step 3.
Step 2 – Screen buildings from outside.
Measure vapor-forming chemicals underground at these locations:
Step 3 – Test indoor air.
Measure vapor-forming chemicals in indoor air, beneath the building’s foundation, and outdoor air at the same time:
Step 4 – Act to protect public health.
Toxic Vapors Can Travel Through Sewer Pipes
Vapor-forming chemicals can enter sewer pipes that run through contaminated soil or groundwater. Once inside a sewer, vapors can move through the pipes and escape through cracks or openings, under or inside a building. Some of the traditional ways to test for vapor intrusion could potentially miss vapor-forming chemicals moving through sewer pipes. This Draft Guidance recommends evaluating whether the sewer could bring toxic vapors inside.
Vapor Intrusion Attenuation Factors
Attenuation factors are used to estimate how much of the vapors underground or in groundwater end up in the indoor air. This Draft Guidance uses attenuation factors recommended by the U.S. Environmental Protection Agency. These were calculated from a large study of buildings at contaminated sites around the nation, including California.
California Vapor Intrusion Database
Data from sites evaluated using the process described in the Draft Guidance will be entered into a database that will be publicly available. The State Water Resources Control Board (State Water Board) added capabilities to the GeoTracker database including building-specific information for a cleanup case and the ability to differentiate Field Points for collecting samples. The State will analyze the information in the database and learn how to better protect the people of California from vapor intrusion.
Where to Find the Draft Guidance
