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What is SPCC Planning
SPCC stands for Spill Prevention Control and Countermeasure. An SPCC is a system in place for the prevention and control of an above ground storage tank (AST) petrochemical spill. For thirty-eight years, SPCC planning has been an important tool in use by the EPA for the prevention of oil, gas, and other petroleum products contamination of the country’s waterways.
Unlike plans for oil spills which focus on cleanup, SPCC planning focuses on prevention, assuring that any spillage from an AST will be contained and that countermeasures are in place to prevent spillage which could result in waterway contamination.
SPCC planning is two fold.
- Implementation of Preventative Measures – Companies are required to assess their tanks, the areas and buildings surrounding their tanks, and their environment to determine how to best implement preventative measures that will make spills less likely.
- Placement of Sufficient Countermeasures – In addition to preventative measures, companies must have actionable countermeasures in place to rapidly stop and clean up any gas, diesel, or other petrochemical spills that may occur.
Those owning or operating an Aboveground storage tank – AST – of 1,320 gallons or more are required by the EPA to have thorough SPCC planning in place to prevent or quickly rectify any spillage or leakage that may occur.
SPCC planning is tailored to each facility’s needs and takes into account the placement of the facility’s ASTs and even USTs should a site exceed 42,000 gallons of storage. There are a general set of requirements under 40 CFR 112 that all facilities implementing SPCC planning must meet.
Inspections and SPCC Planning Adherance
To ensure compliance with all standard SPCC planning measures, the EPA conducts periodic facility inspections. In addition, facilities which have had more than two 42 gallons or more releases or one release of more than 1,000 gallons must hand over detailed information about the spills to the EPA. Fines will be levied for all non-complicit items.
Owners or operators of ASTs which operate for more than four hours per day must keep a copy of their SPCC plans at the facility. If the facility’s ASTs operate less than four hours per day, SPCC plans can be kept at the nearest field office. SPCC plans must be made available to EPA official for review and inspection at the facility site during working hours.
Common SPCC Planning Violations
There are several common SPCC planning violations that are often overlooked or completely ignored by owner or operators of ASTs.
- The facility has no plan in place. [40 CFR 112.3 (a) or (b)]
- Failure of preparation and implementation of SPPC planning. Failure to include elements of a complete plan persuant to 40 CFR 112.3 (c).
- Plans which are not PE certified pursuant to 40 CFR 112.3 (d).
- SPCC plans not reviewed or updated every three years pursuant to 40 CFR 112.5 (b).
- SPCC planning which does not address all appropriate aspects of the facility’s system including transformers, hydraulic systems, emergency generators, drum storage, etc pursuant to 40 CFR 112.7 (e)(2).
- Inaccurate identification of detailed paths that spilled petrochemicals may take to reach waterways. Drains which are not traced out pursuant to 40 CFR 112.7 (e)(1).
- Inadequate, infrequent, or a complete lack of regular walk-through inspections.
- Small, scattered ASTs which are not properly protected from tampering or vandalism pursuant to 40 CFR 112.7 (e)(9).
Oil Related Activities Subject to SPCC Planning
In addition to ASTs, the EPA’s SPCC Guidance for Regional Inspectors documentation cites other petrochemical related activities which fall under SPCC regulation as well.
- Drilling – Drilling of wells to extract crude oil or natural gas and associated products from a subsurface field.
- Production – Extraction of product from wells and separation of the crude oil or gas from other associated products (e.g., water, sediment).
- Gathering – Collection of oil or natural gas from numerous wells, tank batteries, or platforms and transportation to a main storage facility, processing plant, or shipping point.
- Storage – Storage of oil or other petrochemicals in containers prior to use, while being used, or prior to further distribution in commerce.
- Processing – Treatment of oil using a series of processes to prepare it for commercial use, consumption, further refining, manufacturing, or distribution.
- Refining – Separation of crude oil into different types of hydrocarbons through distillation, cracking, reforming, and other processes. Separation of animal fats and vegetable oils from free fatty acids and other impurities.
- Transference – Transference of oil between containers or between stock tanks and manufacturing equipment.
- Distribution – Selling or marketing of oil for further commerce or movement of oil using equipment such as highway vehicles, railroad cars, or pipeline systems. Businesses commonly referred to as oil distributors and retailers frequently store oil, as described above.
- Usage- Usage of oil for mechanical or operational purposes in a manner that does not significantly reduce the quantity of oil, such as using oil to lubricate moving parts, provide insulation, or for other purposes in electrical equipment, electrical transformers, and hydraulic equipment.
- Consumption – Consumption of oil in a manner that reduces the amount of oil, such as burning as fuel in a generator.