Special Topics in Environmental Management

SPCC Plan Checklist: Don’t Leave This Out!

 

( ) A prediction of the direction, rate of flow, and total quantity of oil that could be discharged from the facility as a result of each type of major equipment failure is included in the SPCC Plan in cases when experience indicates a reasonable potential for equipment failure. (Examples may include, but are not limited to, loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge) (40 CFR 112.7(b)).

( ) Appropriate containment and/or diversionary structures or equipment are provided and discussed in the Plan to prevent a discharge. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment system before cleanup occurs. At a minimum, one of the following prevention systems or its equivalent must be used for onshore facilities:

  • Dikes, berms, or retaining walls sufficiently impervious to contain oil
  • Curbing or drip pans
  • Sumps and collection systems
  • Culverting, gutters, or other drainage systems
  • Weirs, booms, or other barriers
  • Spill diversion ponds
  • Retention ponds
  • Sorbent materials
  • For offshore facilities, curbing or drip pans, or sumps and collection systems must be used (40 CFR 112.7(c)).

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( ) A clear explanation is included in the Plan if it is determined that the installation of any of the structures or pieces of equipment used to prevent a discharge is not practicable (40 CFR 112.7(d)).

( ) Provisions are included for bulk storage containers for periodic integrity testing of the containers and periodic integrity and leak-testing of the valves and piping (40 CFR 112.7(d)).

( ) An oil spill contingency plan is included if an FRP has not been prepared (40 CFR 112.7(d)(1)).

( ) A written commitment of manpower, equipment, and materials to expeditiously control and remove any quantity of oil discharged that may be harmful is included in the Plan (40 CFR 112.7(d)(2)).

( ) Provisions for conducting inspections and tests are included in the Plan. Written procedures and a record of the inspections and tests, which have been signed by the appropriate supervisor or inspector, must be retained for a period of 3 years with the SPCC Plan. Records of inspections and tests kept under usual and customary business practices will also be sufficient (40 CFR 112.7(e)).

( ) Oil-handling personnel have been trained in the operation and maintenance of equipment to prevent discharges, discharge procedure protocols, applicable pollution control laws, rules, and regulations, and general facility operations, and are familiar with the contents of the facility SPCC Plan (40 CFR 112.7(f)(1)).


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( ) A person has been designated at each applicable facility to be accountable for discharge prevention and to report to facility management (40 CFR 112.7(f)(2)).

( ) Discharge prevention briefings are scheduled and conducted for oil-handling personnel at least once a year to ensure adequate understanding of the SPCC Plan for the facility. The briefings must highlight and describe known discharges or failures, malfunctioning components, and any recently developed precautionary measures (40 CFR 112.7(f)(3)).

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