What Should Your SPCC Plan Include?

What Should Your SPCC Plan Include?

Thousands of oil spills occur within the U.S. every year, according to the National Oceanic and Atmospheric Administration’s Office of Response and Restoration. Most of these are minor spills amounting to less than a barrel in size, but some over the past 50 years have had a catastrophic impact on the environment and local communities.

For this reason, the Environmental Protection Agency (EPA) has instituted a series of regulations and protocols for organizations to follow if they are to store petroleum responsibly.

One such step is a spill prevention control and countermeasure initiative, more commonly known as an SPCC plan. These plans consist of a series of strategies and protocols to be implemented to minimize the possibility of an oil spill, and while they are more preventive than responsive, SPCC plans are an essential component of a responsible risk mitigation strategy.

What Is an SPCC Plan?

As the name implies, SPCC plans exist to prevent, control, or counteract an oil spill. A proper plan will entail a circumspect set of action steps that can be proactively taken to guard against a spill.

Specifically, SPCC plans are designed to keep oil housed in non-transportation sites away from navigable waters and adjoining shorelines. These primarily include oceans, rivers, lakes, creeks, and streams, but they also cover runoff paths like storm drains connecting to streams or precipitation that could carry oil to nearby bodies of water.

Due to the diversity of non-transportation oil storage systems, many SPCC plans will display variance in the precise standards and protocols that are used. However, there are some universal components that an SPCC plan must include to comply with EPA regulations. Some of the most common requirements are:

  • A thorough site description detailing where all large oil vessels are stored
  • Container volume estimations
  • Oil discharge and flow rate predictions
  • Necessary containment or diversionary structures (berms, bladders, retaining walls, etc.)
  • Drainage mechanism
  • Site security
  • Periodic facility inspections to ensure regulatory compliance
  • Transfer procedures, protocol, and equipment
  • Authorization to handle oil-filled operational equipment
  • Loading/unloading rack requirements and procedures for oil-carrying vehicles
  • Brittle fracture evaluations for above-ground containers
  • Personnel training and prevention briefings
  • Record-keeping requirements
  • Five-year plan review
  • Plan certification by a professional engineer — although self-certification can be an option for certain qualified sites

Physical Safeguards

While some of these action steps listed above are administrative in nature, others are physical mechanisms for handling an oil spill should one occur. Some of these include:

  • Personal protective equipment (PPE) for workers involved in the cleanup. These usually consist of spill kits containing coveralls, goggles, and gloves, as well as booms, skimmer socks, pillows, disposal bags, pads, and even putty to repair small cracks and leaks. A sufficient number of spill kits should be on hand at all times to protect all workers who will be involved in the cleanup of a spill.
  • Drainage systems, including gutters, trenches, and other directory structures that can guide the flow of spilled oil toward a secondary reservoir.
  • Physical structures such as dikes, berms, retaining walls, and bladders. These must be able to hold the full capacity of the containers they enclose, plus additional room to account for precipitation or any water that might be involved in the cleanup of a potential spill.
  • Cleanup equipment, including but not limited to drip pans, sumps, booms, collection systems, and weirs.

The above list is not exhaustive, as the configuration of non-transportation oil storage sites is diverse enough that other factors may need to be taken into consideration as well. However, with the physical and administrative mechanisms in mind, a facility owner/operator may begin to develop an SPCC plan.

Types of SPCC Plans

Although the above implementations provide a framework for general SPCC plans, the specific requirements vary depending on the facility developing the plan. According to EPA guidelines, there are three general types or tiers of non-transportation storage facilities, and the means of SPCC self-certification differ for each — although all can be certified by a professional engineer.

Tier I Facilities

These storage sites have a total capacity of 10,000 gallons of oil or less across all major containers. Vessels holding less than 55 gallons are not required to be included in the 10,000-gallon total. Other requirements are:

  • No single container may hold more than 5,000 gallons.
  • There have not been any discharges exceeding 1,000 gallons that have reached navigable waters within the last three years — or the lifetime of the facility if it was constructed within the last three years. (For example, a site constructed two years ago that has not had a discharge would still qualify as a Tier I facility, even though it has not yet gone three years without a spill.)
  • There have not been any two discharges exceeding 42 gallons that have reached navigable waters within any 12-month period.

Tier I storage facilities are also typically characterized by minimal piping and storage vessels consisting of a few relatively small portable containers. Owners and operators of a Tier I site may self-certify their SPCC plan using an SPCC template found in 40 CFR Part 112, Appendix G, which eliminates unnecessary restrictions and streamlines many requirements for failure analysis, overfill prevention, and bulk secondary containment.

Tier II Facilities

Tier II sites still house less than 10,000 gallons of oil and must also abide by the discharge regulations that apply to Tier I facilities. The primary difference is that they may have at least one container holding 5,000 gallons or more.

Owners and operators of Tier II facilities may also self-certify their SPCC plans, but to do so, they must comply with all applicable requirements laid out in 40 CFR §112.7. Best practice dictates that in the formulation of self-certified Tier II SPCC plans, the regulations for Tier III facilities be applied.

Tier III and Non-Qualified Facilities

In addition to complying with the discharge history requirements of Tier I and Tier II facilities, Tier III sites may house more than 10,000 gallons of above-ground petroleum. Tier III facilities are not qualified for SPCC self-certification and must instead be approved by a professional engineer. Sites that do not meet the discharge history requirements listed above also constitute non-qualified facilities, and hybrid plans may not be self-certified, either.

Creating Your SPCC Plan

Multiple resources are available for consultation in the development of a self-certified SPCC plan. These should all be carefully followed according to SPCC regulations, and those not mentioned above are listed below.

Although, proactive approach is needed in the formulation of an effective SPCC plan, and working in close collaboration with engineers, officials, and regulatory bodies is essential. Consult the resources below to start the process of creating an SPCC plan that will prevent costly oil spills.

Resources to help create your SPCC plan:

1. U.S. Environmental Protection Agency: Spill Prevention, Control, and Countermeasure (SPCC) Rule: Streamlined Requirements for Tier I and II Qualified Facilities

2. U.S. Environmental Protection Agency: Spill Prevention, Control, and Countermeasure (SPCC) Regulation

3. U.S. Environmental Protection Agency: Spill Prevention, Control, and Countermeasure (SPCC) for Agriculture

4. Environmental Works: What Is an SPCC Plan?

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