Special Topics in Environmental Management

The 2 Big Steps to SPCC Compliance

Step 1

The first step is performance-based. This means you have to acquire and maintain the equipment needed to prevent oil spills. In the context of the rule, managers have flexibility in selecting the type of prevention equipment that works best at the best price and ease of operation and maintenance for their specific facilities. Some simple guidelines to follow regarding equipment and equipment selection include:

  • Use containers suitable for the oil stored. For example, use a container designed for flammable liquids to store gasoline.
  • Provide overfill prevention for oil storage containers. You could use a high-level alarm or audible vent.
  • Provide sized secondary containment for bulk storage containers, such as a dike or a remote impoundment. The containment needs to hold the full capacity of the container plus possible rainfall. The dike may be constructed of earth or concrete. A double-walled tank may also suffice.
  • Provide general secondary containment to catch the most likely oil spills where you transfer oil to and from containers and for mobile refuelers and tanker trucks. For example, you may use sorbent materials, drip pans or curbing for these areas.
  • Periodically inspect and test pipes and containers. You need to visually inspect aboveground pipes and oil containers according to industry standards; buried pipes need to be leak tested when they are installed or repaired.

Step 2

The second step, prepare and implement an SPCC plan. Identifying your equipment and describing how that equipment will prevent spills or retain spilled oil are two major elements of the SPCC plan. The federal regulations define the SPCC plan as the “document that details the equipment, workforce, procedures, and steps to prevent, control, and provide adequate countermeasures to a discharge.” Although each SPCC plan is unique to the facility, there are certain elements that must be described in every plan including:

  • Operating procedures at the facility to prevent oil spills.
  • Control measures (such as secondary containment) installed to prevent oil spills from entering navigable waters or adjoining shorelines.
  • Countermeasures to contain, cleanup, and mitigate the effects of an oil spill that has impacted navigable waters or adjoining shorelines.

As you expand the above elements, you will likely touch on many details and facility-specific procedures that are required elements of SPCC plans. These include:

  • Facility diagram and description of the facility
  • Oil discharge predictions
  • Appropriate secondary containment or diversionary structures
  • Facility drainage
  • Site security
  • Facility inspections
  • Requirements for bulk storage containers including inspections, overfill, and integrity testing requirements
  • Transfer procedures and equipment (including piping)
  • Requirements for qualified oil-filled operational equipment
  • Loading/unloading rack requirements and procedures for tank cars and tank trucks
  • Brittle fracture evaluations for aboveground field constructed containers
  • Personnel training and oil discharge prevention briefings
  • Recordkeeping requirements
  • Five-year plan review
  • Management approval
  • Plan certification (by a professional engineer (PE) or in certain cases by the facility owner/operator)