Developing A Spill Prevention, Control and Countermeasure Plan

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Copyright © 2010 Rathi Niyogi


If you operate a facility with above-ground oil storage capacity greater than 1,320 gallons using storage tanks, drums, containers, or utilize equipment that contains oil in excess of this amount, the EPA requires your facility to maintain a Spill Prevention, Control and Countermeasure Plan (SPCC). The facility should also be non-transportation-related, such as oil drilling facilities, oil refineries, oil-tanker and railroad-car-loading facilities, waste treatment facilities, and oil pipelines.

An SPCC plan must go through a process of development, approval, and certification. Development must be handled by the facility in question so as to make sure the plan is specific to the concerns of that facility. Approval must be done by company management, specifically by a manager authorized to implement the plan. And finally, the plan must be certified by a registered professional engineer. Once the plan has passed these steps it must be sent to the EPA Regional Administrator for review. If the administrator reviews the plan and find elements of it unacceptable, at his/her discretion they can require amendments to the plan to bring it within compliance. The plan developers have the right to appeal such decisions and submit written arguments to the EPA.

Failure to follow this process and adequately train personnel to work within a SPCC plan can result in fines of $25,000 per day, per violation. The EPA Administrator may make on-site inspections to evaluate use of the plan, as well as the facility's preparedness.

At the heart of a SPCC Plan is the description of the oil and chemicals used at the facility, as well as the various media used to store or transfer the material between areas of the facility. In question is also the use of containment or diversionary equipment that is on-site to prevent spilled material from reaching waterways. Operating procedures should be clearly outlined, as well as the training and education plans that are implemented to prevent spills, and re-training programs for workers after a spill has occurred. Most of all, a SPCC Plan should specifically outline complete procedures that the facility will follow in the event of a spill, including spill control equipment, communications, and clean-up.

Not all facilities who fall into this category consistently utilize the correct spill control equipment available in the market. Spill control pallets, spill containment berms, drum racks, and overpack drums greatly minimize the risks of spill accidents, provide a strong investment in your SPCC, and demonstrate your commitment to prevention. It would be wise to consider all of these products while devising your SPCC and at the same get management to commit to the budget required to be compliant.


About the Author:
Rathi Niyogi is the CEO of CriticalTool, a national distributor of Spill Pallets and Spill Containment Berms and other safety products. If you thought this article was helpful, additional information on safety storage can be found at http://www.IndustrialSafetyCabinets.com/


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