What does the Oil Pollution Prevention regulation say?

Facilities subject to 40 CFR 112 must prepare and implement a plan to prevent any discharge of oil into or upon navigable waters of the Unites States or adjoining shorelines.  This plan is called a:

Spill Prevention, Control and Countermeasure Plan.

Why do YOU need a SPCC Plan?

Three criteria:

• Facility must be non-transportation related;
• Aggregate aboveground oil storage greater than 1,320 gallons OR buried storage greater than or equal to 42,000 gallons;
• Oil discharge may be expected to reach navigable waters.

What is OIL?

The EPA defines “oil” as oil of any kind or in any form including:

• Fats, oil, or greases of animals;
• Vegetable oils; and
• Other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, oil refuse, or oil mixed with waste other than dredged spoil.

Where Is Oil Stored?
• Aboveground Storage Tanks (ASTs) and containers > 55 gallons
• Underground Storage Tanks (USTs) not already covered by State and Federal UST Regulations ( > 42,000 gallons)
• Oil transfer areas
• Pumps, pipes, controls systems and other tank appurtenances
• Oil-containing equipment > 55 gallons
o Hydraulic elevators
o Oil-containing transformers
o Oil/Water Separators
o Other

Three Main Areas of an SPCC Plan…

1. Operating procedures the facility implements to prevent oil spills;
2. Control measures installed to prevent oil from entering navigable waters; and
3. Countermeasures to contain, cleanup and mitigate the effects of an oil spill.

 
Other important elements of a SPCC Plan

• P.E. Certification
• Facility diagram
• Oil Spill Predictions
• Facility drainage
• Inspections
• Security
• Management review
• Secondary Containment
• Personnel training
• Transfer Procedures

Secondary Containment

• Regulations require secondary containment for containers > 55 gallons.
• Containment must provide capacity for the largest single container PLUS sufficient freeboard for precipitation (generally 110%)
• When there is oil in the containment, clean up the oil following procedure, ID the problem, and fix it!

Security

• Fully fence oil storage areas;
• Lock starter controls;
• Lock drain valves;
• Cap oil pipelines when not in service or stand-by;
• Lighting adequate to discover discharge AND prevent vandalism.

Maintaining YOUR SPCC Plan

• Annual Spill Prevention Briefings;
• Review and modify plan:
• Every 5 years; or
• When there is a change in the facility design, construction, operation, or maintenance that materially affects the potential for a discharge of oil.