Although the Environmental Protection Agency (EPA) wishes to prevent all oil spills in the United States, it also recognizes that spills happen regardless. To ensure a quick response to spills, the EPA emphasizes the importance of preparation and uses several rules and regulations to enforce this. The Spill Prevention, Control, and Countermeasure (SPCC) rule helps facilities prevent spills into navigable waters and adjoining shorelines, and facilities that must comply with this rule are required to develop and implement an SPCC Plan. What is an SPCC Plan?
The SPCC Rule
Before we answer the titular question, “What is an SPCC Plan?”, we need to quickly review the SPCC rule. The rule addresses oil spills, which can endanger public health, jeopardize the safety of drinking water, destroy natural resources, and upset the economy. In addition to the risks posed to human health and the environment, oil spills are expensive; spill prevention costs are typically much less than the costs that arise after a spill, which include clean-up costs, fines, and other civil liabilities. Facilities that store, process, refine, use, or consume oil and that are not related to transportation may be required to comply with the SPCC rule. Compliance includes two parts: preventing oil spills and developing and implementing an SPCC Plan. To find out if the SPCC rule applies to your facility, use this guide on the EPA’s website. So what is an SPCC Plan?
What Is an SPCC Plan?
An SPCC Plan is a document that conveys exactly what your facility will do if an oil spill occurs, demonstrating to the EPA that you are prepared for such an incident. Each SPCC Plan is unique to its facility, but all plans must include the following elements:
- Oil handling operations at the facility
- Spill prevention practices
- Discharge or drainage controls
- Personnel, equipment, and resources at the facility used to prevent oil spills
You will need to describe basic facility information (the owner, location, operations, proximity to waters of the U.S.) as well as information about the oil and petroleum you store (identification of tanks, their contents, their locations, storage capacity, etc.). To prepare for an oil discharge, you must include emergency information in your SPCC Plan, including contact numbers for everyone who must be contacted in the event of a spill and information regarding how to act in the event of a spill. Your facility must prevent spills and describe the procedures used to avoid discharges: tank containment, locking mechanisms, site security, training, inspection information, etc. Finally, you must review your SPCC Plan regularly and conduct training at least once a year to ensure that staff members who handle oil or petroleum at your facility know how to do so properly and how to respond to a discharge.
Although it is a legal requirement, an SPCC Plan is also a tool to help facilities prevent and react to oil spills. Considering the costs that your facility would incur if a spill happened, it is worth your while to create a thorough and reliable plan.
Additional Plan Requirements
There are three types of SPCC Plans: Qualified Tier I Facility, Qualified Tier II Facility, and Non-Qualified Facilities. The type of plan you must complete depends on the aboveground oil storage capacity at your facility, the size of the storage containers, and your facility’s history of oil spills.
A licensed Professional Engineer (PE) must certify your SPCC plan unless your facility qualifies for self-certification by the facility owner/operator. The PE must be familiar with the SPCC rule, visit and examine your facility, confirm that your SPCC Plan has been prepared in accordance with good engineering practices (including the SPCC rule’s requirements and any applicable industry standards), affirm that you’ve established procedures for the required inspections and testing, and verify that the plan is satisfactory for your facility. If an owner/operator chooses to self-certify, he or she must make a similar statement (source).
If you aren’t able to prepare and implement your SPCC Plan by the compliance date due to (1) qualified personnel being unavailable or (2) a delay in construction or equipment delivery that is beyond your control, you may request an extension. Contact your EPA Regional Administrator for more information.
Although the plan fulfills requirements set by the EPA, you do not need to submit it to the EPA. You must, however, maintain SPCC Plans at any facility that is normally attended at least four hours per day. If your facility is not attended by staff in this way, you must maintain the plan at the nearest field office. Finally, upon request, you must submit your plan to the EPA.
If your facility needs help creating an effectual and compliant SPCC Plan, contact Environmental Works today. Our experienced environmental consultants assist companies of all sizes with environmental challenges and compliance issues. Plus, we offer a three-hour Spill Prevention Control and Countermeasure (SPCC) Training course. This annual training is required for any organization that is required to have an SPCC Plan by the EPA, and you must keep proof of this training in your records. For more information about EWI’s services, please contact us online or give us a call at 417-890-9500.