Monthly Archive: May 2015

Protect yourself with a certified SPCC

If your company maintains a total aboveground oil storage capacity of greater than 1,320 gallons, or a total underground oil storage capacity of greater than 42,000 gallons located where there is a “reasonable potential” for a discharge to reach navigable waters, your company is subject to Spill Prevention Control and Countermeasure (SPCC) regulations. The U.S. Environmental Protection Agency (EPA) requires SPCC plans in an attempt to prevent oil from entering navigable waters and adjourning shorelines, which can have a costly impact on the environment and your financial bottom line.

Of note: Aboveground storage containers with a capacity of 55-gallons or more are included in the aboveground capacity threshold calculation. Underground storage tanks regulated under 40 CFR 280 and 281 are not subject to the SPCC regulations. Neither are operations that exist to move oil from one location to another.

Oil of any type and in any form is covered, including petroleum, fuel oil, sludge, oil refuse, oil mixed with wastes other than dredged spoil, fats, oils or greases of animal, fish, or marine mammal origin, vegetable oils and other oils and greases such as synthetic and mineral oils.

The trick can be determining whether or not your storage containers possess the “reasonable potential” for a discharge to reach navigable waters.” When determining that, consider:

  • The geography and location of your facility relative to nearby navigable waters such as streams, creeks and other waterways
  • Whether ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby streams
  • The estimated volume of oil that could be spilled in an incident and how that oil might drain or flow from your facility and the soil conditions or geographic features that might affect the flow toward waterways
  • Whether precipitation runoff could transport oil into navigable waters or adjoining shorelines

You should not take into account manmade features such as dikes, equipment, or other structures that might prevent, contain, hinder, or restrain the flow of oil. Assume those features are not present when making your determination.

If you consider the factors described above and determine a spill can reasonably flow to a waterway, then you must comply with the SPCC rule by developing and implementing an SPCC plan.

Prepare and implement an SPCC plan that describes oil handling operations, spill prevention practices, discharge or drainage controls, and the personnel, equipment and resources used at the facility to prevent oil spills from reaching navigable waters or adjoining shorelines. Each company’s SPCC plan needs to be unique and specific to that company. But, some elements must be describe in every plan:

  • Operating procedures at the facility to prevent oil spills
  • Control measures (such as secondary containment) installed to prevent oil spills from entering navigable waters or adjoining shorelines
  • Countermeasures to contain, cleanup, and mitigate the effects of an oil spill that has impacted navigable waters or adjoining shorelines

Every SPCC plan must be prepared in accordance with good engineering practices. Preparation of the SPCC plan is the responsibility of the facility owner or operator. Unless you meet certain criteria that allows for self-certification, your SPCC plan must be certified by a licensed professional engineer. The engineer will confirm the plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards, and with the requirements of the rule; procedures for required inspections and testing have been established; and the SPCC plan is adequate for the facility.

No matter who certifies your SPCC Plan, remember that ultimately the owner or operator is responsible for complying with the rule. A copy of the rule is available at www.epa.gov/oilspill.

If your company needs assistance with creating, updating or implementing its SPCC plan, SSCI can help. We’ve written or updated SPCC plans for a variety of client types, including more than 320 plans for the Texas Department of Transportation facilities.

Spill-prevention tips

A significant part of your SPCC plan will be focused on oil spill prevention. Here are some tips on how to do that:

  • Use containers suitable for the oil stored
  • Provide overfill prevention for your oil storage containers. You could use a high-level alarm or audible vent
  • Provide sized secondary containment for bulk storage containers, such as a dike or a remote impoundment. The containment needs to hold the full capacity of the container, plus possible rainfall. The dike may be constructed of earth or concrete. A double-walled tank may also suffice
  • Provide general secondary containment to catch the most likely oil spill where you transfer oil to and from containers and for mobile re-fuelers and tanker trucks
  • Periodically inspect and test pipes and containers. You need to visually inspect aboveground pipes and oil containers according to industry standards. Buried pipes need to be leak tested when they are installed or repaired. Include a written record of inspections in the plan

Have a plan in case of hazards

The federal government requires all companies that have hazards in the workplace – and who doesn’t? – have a proper Health & Safety Plan (HASP). Every company that has more than 10 employees is required to have at minimum a written Emergency Action Plan and Fire Prevention Plan. For more hazardous activities, OSHA requires companies to have their own individual hazard plan. For example, if employees are working more than six feet above the ground for any reason or any duration, your company must have Fall Protection.

HASPs set a standard for employees to follow and work by and allow for discipline and enforcement if employees aren’t adhering to the practices. More than that, a HASP shows your employees that you’re committed to their safety.

It’s essential to keep your HASP updated to address today’s hazards. After all, you don’t want to be cited by OSHA because that plan you worked so hard on is out of date.

But creating a plan that meets OSHA standards can be complex. That’s where SSCI can come in.

We’ve written HASPs for government entities, small firms and companies with 500 employees. SSCI employees don’t just sit in the office and write about safety theories; we work onsite with construction companies. Because of that, we’re uniquely qualified to create and implement HASPs.

SSCI has also provided consulting services for companies with OSHA violations and aided in the abatement of those violations. That’s experience that can really help you out of a tough situation – or help you avoid one altogether.

SSCI offers several levels of HASP services:

  • We can do a safety audit of your workplace, which includes a review of your HASP and recommendations on how to strengthen it.
  • Since most plans require at least an annual update, we can review and update your plan.
  • We can create a brand new, from-scratch plan unique to your company. This starts with a meeting to determine which written plans are mandatory.
  • We can train your employees in the new plan. Or we can help you do it in-house, saving you the expense of a full day of training.
  • After writing your plan, we can do a six-month (or sooner) quality-assurance/quality-control check-up to ensure implementation is going smoothly.

If you need a HASP, or your HASP needs updated, we can give you a FREE consultation.