6 Tips for Complying with SPCC Regulations
For centuries, humans contaminated drinking water with raw sewage, unaware that such actions were the source of diseases like cholera and typhoid. Large factories and manufacturing plants that exploded into the scene during the Industrial Revolution poured pollutants directly into rivers and streams, because it was convenient and they didn’t know any better. The Cuyahoga River fire of 1969 and subsequent negative national media coverage finally inspired the Clean Water Act (CWA) to reduce water pollution.
The CWA embodied a new federal-state partnership. Federal guidelines, objectives and limits were set under the authority of the U.S. EPA. Spill Prevention, Control and Countermeasure (SPCC) is part of the CWA found in 40 CFR 112. Designed to prevent oil discharges from reaching navigable waters of the U.S. or adjoining shorelines, SPCC regulates any site that stores, processes, refines, uses or consumes oil.
Three criteria for a facility to be subject to SPCC regulations include:
- Non-transportation-related facility that handles oil or oil products
- Stores more than 1,320 gallons of oil above ground or more than 42,000 gallons below ground
- Has a reasonable expectation of discharge into navigable waters (or adjoining shorelines)
To ensure compliance, develop an SPCC plan for your facility. This describes how your facility will prevent, respond to and control spill events. If an incident occurs, EPA inspectors evaluate your performance against your SPCC plan.
The following six tips highlight key elements of a plan and how to put them into practice:
SPCC Regulation Compliance: Tip 1
Create an SPCC Plot Plan Showing Storage Locations and Volumes
An SPCC plot plan helps identify high risk areas and develop control and countermeasures. To prevent and control spills, document all potential spill sources. The plot plan should detail storage locations, material in storage and volumes.
This information is also critical for emergency response. Responders need to know the site layout and the materials they will encounter. Include the contact details of key spill management personnel on the plot plan.
SPCC Regulation Compliance: Tip 2
Calculate Potential Spill Volumes and Flow Rates
Develop scenarios to determine where the risks exist in your facility. How much oil is stored on site? Which material has the greatest environmental impact? Which tankage and piping system is aging and requires special attention? Which storage location is closest to navigable waters?
SPCC Regulation Compliance: Tip 3
Develop Inspection Plans, Procedures and Record Keeping
Catching a leak early is critical to prevent contamination of waterways. Routine inspection programs with accurate record keeping are a preventative measure.
Inspect tankage and piping for leaks. Check secondary containment areas to see if they contain product. Regularly monitor fuel and filling processes along with the associated equipment.
SPCC Regulation Compliance: Tip 4
Every employee should know what hazardous materials are used on the site. They should also understand the reporting procedure in the case of a spill.
Train those required to respond to a spill. They need to know how to handle the spill response equipment and how to use the personal protective equipment (PPE).
Also, regularly review training materials to ensure all employees know how to perform their duties in a way that minimizes the potential for spills.
SPCC Regulation Compliance: Tip 5
Implement Discharge Prevention Measures
Develop procedures that cover routine daily tasks and abnormal operations. This is particularly important for operations involving oils, like loading and unloading. Another high-risk function is the release of water from secondary containment areas.
SPCC Regulation Compliance: Tip 6
Use and Document Secondary Containment Systems
Secondary containment systems contain oil spills in one location until cleaning can occur. Passive secondary containment systems do not need human intervention to contain a spill. Examples of passive systems include flexible containment berms such as Justrite’s patented Rigid-Lock QuickBerm®. Chemical and abrasion resistant, it can be used for a variety of containment applications. With no assembly required, it is the most user-friendly designed spill containment berm on the market.
Active secondary containment requires people to take some action for spill containment. Due to staff shortages and lack of resources, active containment is not appropriate for all situations. Placing Storm Water Drain Covers over a storm water drain as a last defense to prevent run-off is an example of active containment. Using a spill kit for spill response is also active containment.
Order Justrite Spill Containment Products to Comply with SPCC Regulations Today
Justrite offers technical support for your SPCC requirements. We supply a comprehensive range of collapsible berms for spill containment and customize our products to fit your needs. Find out more here.Question or Quote?
- EPA. Overview of the Spill Prevention, Control, and Countermeasure (SPCC) Regulation
- Technical Response Planning. The SPCC Plan Template and Compliance Components.
- RMA Environmental Services. What is a SPCC Plan?