SPCC Plans – Some Pitfalls of Oil Spill Prevention, Control, and Countermeasure Compliance

This article is available as a podcast episode on ALL4’s Air Quality Insider

Does your facility have a Spill Prevention, Control and Countermeasure (SPCC) Plan?  When is the last time you reviewed it?  Is it up to date?  Have you kept track of all minor facility changes that materially affect potential discharges?  Are you on track to complete your required 5-year plan review?  Have you performed your annual SPCC Plan Training?

SPCC Plans require routine review to maintain the plan’s effectiveness.  This is especially true with the additional requirements for oil storing and producing facilities.  Complacency is probably the number one reason why plan reviews are delayed or forgotten altogether.  Once your plan has been updated, it may only be good until the next change at the facility, which trigger revision deadline.  In my experience in the oil and gas industry, SPCC Plans are considered low risk and therefore fall off your radar if you aren’t careful.  With just a little bit of planning, SPCC Plans can stay current and up to date with minimal stress.

What is an SPCC Plan?  Let’s Review the Basics!

SPCC plans were introduced under the Clean Water Act of 1973 and their requirements were amended by the 1990 Oil Pollution Act.  The implementing regulations are at 40 Code of Federal Regulations (CFR) Part 112 (Oil Pollution Prevention).  Facilities are subject to SPCC requirements if they have the capacity to store more than 1,320 gallons of oil aboveground in containers with a capacity of 55 gallons or more, or 42,000 gallons of oil in completely buried storage below ground.  Once requirements are triggered, facilities must develop and implement an SPCC Plan before bringing oil onsite.  SPCC Plans require secondary containment for aboveground bulk oil storage which accounts for the largest container within the containment area plus adequate room for precipitation.  While subjective, adequate room for precipitation is generally considered to be enough for the largest 24-hour rainfall event in the previous 25 years. 

Key Plan Milestones in your SPCC Plan?

Once your plan has been created, a laundry list of compliance items need to be managed in order to maintain compliance.  There are additional items if you own or operate an oil storing or producing facility to watch out for in 40 CFR Part 112 Subpart B, but the general requirements are on this list which includes: 

• Every five years the entire plan needs to undergo a review
• Every year you must conduct annual SPCC training
• Every year you must conduct an Tank and Berm Inspection
• Every time there is a change in the facility design, construction, operation, or maintenance that materially affects the potential for a discharge (e.g., the oil capacity changes), you have six months to update and recertify the plan

These items are all on different timelines and deadlines are easily missed.  A 5-year review requires a thorough review of your site’s plan, and as a result, can take more than a few hours to complete.  Procrastination could result in missing your deadline for addressing required SPCC Plan amendments.  If the 5-year plan review is not specifically identified on a compliance calendar, consider adding. 

Other easily overlooked requirements are the tank and containment inspections as well as employee training.  Each is required and can sneak up on you given the number of other compliance obligations at a Facility.  The inspections allow operators to discover leaks and determine if tank and containment conditions have changed as part of a spill prevention program.  Annual training is required for all oil handling personnel.  These two tasks were incredibly challenging when working in industry, because without proper planning, you could end up repeating the task and generating extra work.  Driving out to facilities a second time to complete missed inspections, or repeating trainings for the few who missed out on a training, can take more time than originally anticipated.

The last and potentially most frustrating compliance item is the 6-month update.  The rule requires that any change in the facility design or operation that could affect potential spills to trigger an update within 6 months of the change.  The most common cause for overlooking a 6-month update is poor communication regarding facility changes.  If you aren’t aware of facility changes, this could lead to holes in your SPCC Plan. 

Take action!!!

If you haven’t checked on your SPCC Plan, have questions about compliance, or are running close to a deadline feel free to reach out to me at (281) 937-7553!  If you need help complying with SPCC requirements, ALL4 can help save you the headache.