workers in safety gear evaluating a spill

SPCC plans: minimizing risk, maximizing benefits

Author: Christopher Harp, CSP, Senior Legal Editor

Oil spills have always been a risk for industrial operations. Thankfully, large-scale, catastrophic oil spills such as the 2010 Deepwater Horizon disaster, conjuring up images of devastated ecosystems and oil-soaked wildlife, are rare occurrences. Smaller spills, though less catastrophic, are much more common and still cumulatively inflict significant environmental damage.

In fact, according to the Environmental Protection Agency (EPA), a one-gallon oil spill can contaminate a million gallons of water. The federal Spill Prevention, Control, and Countermeasure (SPCC) regulations provide a framework for oil storage facilities to prevent oil from reaching navigable waters and adjoining shorelines, and to contain discharges of oil.

Applicability

SPCC regulations apply to facilities that:

  • Are non-transportation-related;
  • Are engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using or consuming oil;
  • May be reasonably be expected to discharge oil in quantities that may be harmful into navigable waters or adjoining shorelines; and
  • Have total aggregate capacity of aboveground oil storage containers is greater than 1,320 gallons of oil (Not counting containers less than 55 gallons, permanently closed containers, motive power containers, or storage containers used exclusively for wastewater treatment); or
  • Have total aggregate capacity of completely buried storage tanks greater than 42,000 gallons of oil.

Make a plan

If your facility meets these criteria, an SPCC plan is needed. This plan describes oil handling operations, spill prevention practices, discharge or drainage controls, and the personnel, equipment and resources at the facility used to prevent oil spills from reaching navigable waters or adjoining shorelines. It’s crucial to keep the SPCC plan updated and readily available at the facility.

Although each SPCC plan is unique to the facility, there are certain elements that must be described in every plan including:

  • Spill prevention operating procedures, such as monitoring and tank design
  • Spill control measures, such as secondary containment
  • Mitigation and cleanup measures if an oil spill does occur

Certification

Once the plan is complete, it must be certified by a Professional Engineer (PE), with a few exceptions. Facilities may self-certify if the facility total aboveground oil storage capacity is 10,000 gallons or less, and in the three years before the SPCC Plan is certified, the facility has had no discharges to navigable waters or adjoining shorelines of a single discharge of oil greater than 1,000 gallons, or two discharges of oil each greater than 42 gallons within any 12-month period.

Many states have adopted federal regulations. Check your state’s individual regulations via their environmental agency website for stricter requirements and additional resources.

Compliance is a win-win for employers and the environment

Compliance with SPCC requirements offers benefits encompassing environmental, financial, and operational aspects for employers.

Below are some key advantages:

  • Environmental protection: When preventative measures outlined in the SPCC plan are implemented, the likelihood of spills occurring is reduced. Additionally, if a spill does occur, a compliant SPCC plan ensures your facility has the proper measures in place to contain and control it quickly, therefore minimizing the spread and the damage to the environment.
  • Cost savings: Prompt containment and response according to the SPCC plan can reduce the cleanup costs associated with a spill if one happens in comparison to a situation where proper preparations weren’t put in place. Fines and penalties due to non-compliance with SPCC regulations can also be financially devastating. Employers who remain compliant can mitigate that risk and the potential legal action that can come with it.
  • Operational efficiency: Employers who emphasize the importance of following procedures outlined in the plan and the proper training; it contributes to a safer work environment for their employees. It can also minimize operational disruptions and downtime caused by cleanup efforts. Lastly, demonstrating environmental responsibility through SPCC compliance can improve a facility’s reputation and standing within the community.

Overall, complying with SPCC requirements is more than just a legal obligation. It’s a win-win for facilities, the environment, and the community.

Minimize the threat to public and environmental health with immediate and compliant spill response

In the unfortunate event of a toxic release or spill, time and appropriate reporting are essential. BLR can help you respond with the appropriate state, local and federal authorities.