SPCC Plan

SPCC Plan BackgroundDonwload Pdf

  • 40 CFR 112
  • Initiated by the Clean Water Act, a Federal Law passed in 1972
  • Response to large oil spills that contaminated oceans or rivers
  • Meant to protect surface water, but also protects soil and groundwater

Who is considered a farm?

A facility on a tract of land

  • devoted to the production of crops or raising of animals, including fish, which produced and sold, or normally would have produced and sold, $1,000 or more of agricultural products during a year.

When? – MAY 10, 2013

  • Unless your farm was in operation before 2002, then you should already have one in place.
  • No enforcement for 180 days after May 10, 2013

Who is required to have a plan?

  • Any facility reasonably expected to discharge harmful amount of oil into navigable waters of the U.S.
  • Any facility with an above ground storage capacity of 1,320 gallons of oil

Or

  • Any facility with underground storage of more than 42,000 gallons of oil

“Oil” includes

  • Fats
  • Oil or greases of animal, fish or marine mammal origin
  • Vegetable oils
  • Crop oil
  • Petroleum
  • Diesel Fuel
  • Fuel Oil
  • Gasoline
  • Oil refuse, waste or sludge
  • Synthetic Oils
  • Mineral Oils
  • Lube Oil
  • Hydraulic Oil
  • Adjuvant Oil

When determining, Include:

  • Any container over 55 Gallons
  • Use capacity, not the amount actually in it at the time
  • Fuel tanks mounted on trailers, fuel trucks used exclusively on the farm and tanks in pickups
  • Transformers
  • Both inside and outside containers

But don’t include:

  • Containers smaller than 55 gallons
  • Heating oil used solely for a single family residence
  • Milk containing equipment
  • Pesticide application equipment
  • Permanently closed tanks
  • Ammonia tanks or any other non-oil substance

Requirements of the SPCC rule – Requires certain facilities, including farms, to develop and implement a site-specific SPCC plan to address:

  • Containment and procedures to prevent oil discharges
  • Proactive control measures to keep an oil discharge from entering navigable waters of the US
  • Effective countermeasures to contain, clean up and mitigate any oil discharge

Are you Tier I or Tier II?

You are a Tier I Facility if

  • Your total capacity is less than 10,000 gallons in aggregate aboveground and,
  • for the past 3 years, have not had a significant spill (single discharge of 1,000 gallons or 2 discharges within 12 months of 42 gallons or more each)

Everyone else is Tier II

Tier I facilities

  • Tier I facilities may prepare and self-certify their own plan if no container is larger than 5,000 gallons
  • Use EPA template on their website.

Tier II facilities

  • Tier II facilities must have plan certified by a licensed professional engineer (P.E.)

The SPCC process

  • Evaluate risks
  • Prepare an SPCC Plan
  • Design improvements for spill prevention and containment
  • Implement plan
  • Perform training

Where to start:

  • With a full inventory of what oil is on your property
  • Non-oil substances are not required in your plan, however, if you wanted to add them, you may identifies ways spills might occur
  • Describes what has been done to prevent a spill
  • Details how to handle a spill

An SPCC Plan

An SPCC plan…

  • Does not get submitted to any particular agency unless asked for. It must be available immediately if requested.
  • If facility is “manned” 4 hours per day or more, written plan must be kept on site.

Who might ask to see my plan?

  • Storm water inspectors
  • County agencies
  • Watershed commissions
  • Waste water treatment plants
  • Water treatment plants
  • Ohio EPA inspectors
  • Federal EPA inspectors
  • Etc, etc…

Components of an SPCC plan

All drums, containers and equipment

  • Sealed and free from cracks, corrosion, and damage
  • Stored upright
  • Not sitting directly on the ground to prevent corrosion

Security Procedures

  • Fencing
  • Lighting
  • Internal Communication
  • Controlled Entrances/exits and alternate access

 

Inspection Procedures

Schedule Inspections

  • Perform monthly checklist
  • Perform annual checklist
  • Correct any shortcomings
  • Check for integrity of containment structures
  • Leaks from pipes, valves, or containers
  • Corrosion on pipes and tanks
  • Proper drainage from all drains (inside and outside)
  • Spill kits are available and stocked
  • All tanks and containers are correctly labeled
  • Chemicals are in designated areas
  • Empty drums are inspected, cleaned, and stored in designated areas only
  • Report any discoloration on ground, walls or floors indicating leaks or contamination
  • Inspect security systems for signs of vandalism
  • Inspect any areas of previous spills

Housekeeping

  • Clean up trash, spills, and leaks
  • Trash should be collected regularly

Secondary containment:

SPCC Regulations say that any container larger than 55 gallons must have secondary containment sized to hold 110% of the capacity.

  • Double walled tanks – Priced around – $1,700 for a 550-gallon tank, $3,650 for a 1,000-gallon tank
  • Concrete containment or dike
  • For an interior location – Spill pallets

Tip – Be sure what you purchase can hold 110% of the largest container stored on it.

But outside – How do you let out the rain while keeping in the oil?

Manual valves – After inspecting accumulated rainwater for sheen, open valve to release water

Problems:

  • Must remember to shut valve – good idea to use a locking ball valve
  • Must remember to drain containment after rain event

Chemical barriers – There are a number of products available that allow rain and snowmelt to flow freely, but consist of a polymer that reacts with oil to form a solid barrier.

These include:

  • Petro-Pipe
  • Hydrocarbon flow filters
  • CIAgent Barrier Boom
Other mechanical means:

  • Oil-water separator
  • Various systems with automatic shut off valves
  • Pump is shut down when float-activated switch reaches certain position

Your SPCC must give instructions for how to handle a spill

  • What spill equipment is on-site
  • What personal protective equipment (PPE) is available
  • Notification process and phone numbers

Spill Response Kit Contents – Each spill kit should contain:

  • Bags of Adsorbent
  • Material
  • Rubber Boots
  • Gloves
  • Disposal Bags and Ties
  • Container Overpack
  • Safety Glasses
  • Hardhats with Face Shields
  • Pigs
  • Drain covers
  • Mats

Reportable spills – This part applies to everyone, whether you are required to have an SPCC plan or not.

What is a REPORTABLE spill?

  • 25 gallons or more of oil that gets offsite
  • Or an amount that causes a sheen on water in a creek, river, or storm sewer

Spill Notification

Verbal notification of a reportable release must be made within 30 minutes of the discovery of the spill.

Agencies to report the incident-

VERBAL reports must be made to the following agencies:

  • Local Fire Department – 911
  • National Response Center – 800-424-8802, or online at www.nrc.uscg.mil/nrchp.html
  • Ohio EPA Emergency Response Center – 800-282-9378
  • County Emergency Coordinator:
Shelby: 937-492-5635

Logan: 937-593-5743

Champaign: 937-484-1642

Miami: 937-339-6400

Darke: 937-548-1444

Mercer: 419-586-6468

Auglaize: 419-739-6725

Written notification of reportable release must be made within 30 days of the spill.

Written reportable Spill Notification to:

  • Ohio EPA
  • County Emergency Coordinator
  • Local Fire Department

Training Requirements

  • Training is performed annually or whenever a change is made to the plan.
  • Training shall be conducted for all new employees of the facility.

RESOURCES

Go here for the EPA SPCC sample plan/template, with text to borrow!

http://www.epa.gov/osweroe1/docs/oil/spcc/sample_plan.pdf

Need help? Go here is an online guide for filling out the SPCC template:

https://www.asmark.org/mySPCC/