Requirements for valid SPCC Plans
SPCC plan is required to prevent oil spills.
The SPCC plan gives the EPA assurance the location has a process in place to prevent spills from the above ground tank. Typically these plans make sure the site has the proper mechanism & equipment to contain spills.
- Elements of the plan also list the countermeasures that are used to prevent oil spills.
- In the event a spill occurs, regulators believe that an EPA SPCC plan will prevent an oil spill from impacting streams, creeks, lakes, ponds and other surface water.
- SPCC plans are not spill contingency plans which focus solely on the actions taken AFTER a spill has occurred.
SPCC Requirements are classified in 3 Tiers
Every tier has its own set of requirements. The storage capacity will determine which Tier’s requirements must be followed. Regardless of the classification, all SPCC plans must be prepared in accordance with the oil pollution prevention guidelines in the Federal Code of Regulations 40 CFR, 112.
Tier I SPCC Qualification Requirements- Small facilities:
- containing 10,000 gallons or less aggregate above ground petroleum storage capacity.
- storage is calculated by adding up all the above ground oil storage capacity at your location. When making this calculation, add up all oil containers that hold at least 55 gallons. You do not have to add any container that holds less than the 55 gallon amount.
- within any twelve-month period, three years prior to the Plan certification date, there has been no single discharge of petroleum to navigable waters or adjoining shorelines exceeding 1,000 gallons and
- no two discharges of petroleum to navigable waters or adjoining shorelines each exceeding 42 gallons.
- has little or no piping. These sites have a few low capacity oil storage containers, some mobile or portable container and very few oil transfers.
Streamlined SPCC Plan & Self-certification permitted: If the above Tier I SPCC requirements are met, an owner or operator may complete and self-certify plan template instead of a full Professional Engineer certified plan. Tier I class may also prepare an SPCC plan according to Tier II requirements. Owners can also use a template which makes the process easier but is not without pitfalls.
Tier II SPCC qualification requirements- Mid-sized facilities:
- storing 10,000 gallons or less aggregate above ground petroleum storage capacity,
- no individual above ground petroleum storage container greater than 5,000 gallons and
- site meets all other Tier I discharge conditions.
Self certification is allowed but a full SPCC plan is required: If the above Tier II requirements are met, an owner or operator may self-certify a spill plan in accordance with requirements of 40 CFR, 112.7, in lieu of a professional engineer certified plan. In these cases, it’s highly recommended that the facility prepare a full SPCC plan according to all other Tier III requirements.
Tier III SPCC requirements- Large facilities:
- storing more than 10,000 gallons aggregate above ground petroleum storage capacity and
- must meet all other Tier I and Tier II discharge conditions.
Full certified SPCC plan required: A licensed professional engineer must prepare and certify the plan for Tier III sites in accordance with all the applicable requirements of §112.7. See a sample SPCC Plan and its requirements.
6 Most Common Deficiencies
In our experience, most large facilities already have an SPCC plan in place. Because the EPA issued new SPCC regulations, the SPCC plan probably needs updating to meet new requirements. We’ve reviewed many existing plans and have seen deficiencies in areas where regulators are most likely to examine. Here are six common problems that fail to meet SPCC requirements.
- Inaccurate facility diagrams & descriptions. We find that owners forget to update this material. Any site modifications or improvements must be reflected in the diagram & description.
- Missing state or local requirements. Unfortunately, the EPA is not the only government entity that has rules governing this area. States and some local jurisdictions have their own requirements and often are not included in the SPCC plan.
- Improper process for brittle fracture. Brittle fracture evaluations must be performed & a certain inspection process must be followed.
- No monitoring of heating coils. Many SPCC plans require monitoring of internal heating coils. This requirement is often missed.
- Improper Recording of Prior Spills. Any spills occurring at the facility must be properly documented. Many plans we review do not have documentation detailing the corrective action taken or a procedure to prevent them from happening again.
- No description as to the impact of a potential release. Most plans will require a written statement that predicts the rate of flow and total quantity of oil that could be discharged when there is equipment failure at the location.
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12 Basic Requirements of any SPCC Plan:
- Description of any spills in the last twelve months, including:
- corrective action
- plans to prevent recurrence.
- Layout of facility, including diagrams marking location(s) and contents of:
- all oil storage containers
- all buried tanks
- any transfer stations
- all connecting pipes
- Predictions of the direction, rate of flow, and total quantity of oil that could be discharged.
- A complete explanation of spill containment and any diversionary structures or equipment including:
- Retaining walls
- Culverts, gutters, or other drainage systems
- Spill diversion/retention ponds
- Double-wall tanks with interstitial monitors
- Absorbent materials
- Facility maintenance of containment area drainage:
- Storm water in berms and dikes
- Dike drainage practices
- Management of areas that are not contained
- Bulk storage practices:
- Verification that tank material and construction are compatible with material stored
- Secondary containment means such as double walled tanks or physical containment with a capacity equal to the largest tank plus 10%.
- Procedure to ensure that drainage of containment area does not release oil and the type of system to document compliance.
- Integrity testing procedures and record keeping
- Transfer protocol, including:
- Means to limit corrosion of buried piping
- Means to inspect and maintain above-ground valves and piping
- Procedures to warn vehicles to avoid damaging above-ground piping and storage, where appropriate
- Tank truck loading and unloading practices, including:
- Documentation that loading and unloading procedures meet Department of Transportation (DOT) requirements
- Loading/unloading area containment capacity (i.e., at least the capacity of the largest single compartment of the vehicle being loaded or unloaded) and containment method
- Means to prevent vehicle departure before transfer lines are disconnected
- Inspection and documentation means to assure the plan is being implemented. (All records must be maintained for at least three years.)
- Site security:
- Restriction of access to oil handling and storage areas
- Means to secure tank valves, pumps, and loading and unloading connections when in standby status
- SPCC training programs, including:
- Operation and maintenance of equipment
- Applicable environmental regulations and requirements overview
- Designation of an SPCC Plan coordinator
- Training schedule
- Personnel training records
- A “Certification of the Applicability of Substantial Harm Criteria” form. If all five questions on this form are answered ‘no’, then the form is a required part of the SPCC Plan. A ‘yes’ answer to any question on the form will require submitting a facility specific response plan to the EPA.
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