Don’t Leave These Out!
In your SPCC plan, security procedures must include provisions to:
- Secure and control access to each facility’s handling, processing, or storage areas.
- Secure master flow and drain valves.
- Prevent unauthorized access to starter controls on oil pumps.
- Secure out-of-service and loading/unloading connections of oil pipelines.
- Address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges.
Owners and operators of regulated facilities may tailor security measures to the facility’s specific characteristics and location.
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Common SPCC Violations–Security
If an inspector is looking at your plan, he won’t forget about the security section. Avoid these most common violations with regards to security.
- Facility security measures are not mentioned in the SPCC plan.
- Facility lighting is not addressed in the SPCC plan.
- The plan lacks procedures to secure tank master flow/drain valves and starter controls.
Help! Industry Standards
There are a few industry standards out there to help you out.
- API Standard 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities
- NFPA 30A, Automotive and Marine Service Station Code, Flammable and Combustible Liquids Code
A PE should also be familiar with any applicable standards.
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SPCC Security Training Tips
It isn’t enough to put it in your plan—you also have to train your workers on security measures. Here are a few common security measures you can share with your workers in training.
Flow and drain valves. Make sure that the master flow and drain valves on containers and any other valves that permit direct outward flow of a container’s contents to the surface have adequate security measures so they stay closed when not in use.
Pump controls. Lock the starter control on each oil pump in the "off" position and make sure it’s accessible only to authorized personnel when the pump is turned off.
Loading and unloading connections. Cap or blank-flange the loading and unloading connections of all pipelines when they’re not in service or when in standby service. This security practice also applies to empty pipes.
Lighting. Make sure there is enough lighting to assist in discovery of spills when it is dark, even by police or passersby, and to deter vandals.
Identify all personnel. Immediately notify your supervisor about any suspicious activity or people who don’t belong there.
See tomorrow’s Advisor for an SPCC security checklist you can use to make sure you’re covered.