DOES YOUR COMPANY NEED AN SPCC PLAN? Larry Seabolt Remtech Engineers Remediation Specialists

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1 DOES YOUR COMPANY NEED AN SPCC PLAN? Larry Seabolt

2 What is a Spill Prevention, Control and Countermeasures Plan? Is your company required to have a SPCC plan? What constitutes a SPCC plan? The answer to these questions and the guidance for the preparation and implementation of an SPCC plan follows.

3 What is a Spill Prevention, Control and Countermeasures Plan? A document required by 40 CFR that details the equipment, workforce, procedures and steps to prevent, control, and provide adequate countermeasures to a discharge. Or simply stated, a plan required in the 40 CFR on what is needed to prevent a discharge or in the event of a discharge what to do to control and clean up the release.

4 Basis for the SPCC Plan Part of the Clean Water Act (originally the Federal Water Pollution Control Act of 1972) Protects the navigable waters, adjoining shorelines and waters of the contiguous zone from pollution Requires facilities that could reasonably be expected to discharge oil in quantities that may be harmful into navigable waters and adjoining shorelines to develop and implement SPCC plans.

5 What is oil? Oil means any kind or in any form, including but not limited to: fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits or kernels; and, other oils and greases including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil.

6 Original SPCC The original SPCC regulations were promulgated in 1973 Changes have occurred through revisions, the last of which were in 2002 Established regulations for non-transportation facilities with an aboveground storage capacity greater than 1,320 gallons or a buried storage capacity greater than 42,000 gallons.

7 Does your facility meet the requirements? You are not a transportation related facility You have a product or products that could cause harm to waterways of the United States You have above ground storage in a capacity greater than 1,320 gallons or below ground storage in excess of 42,000 gallons

8 Does your facility meet the requirements? If you answered yes to the previous questions, then your facility needs a Spill Prevention, Control and Countermeasures (SPCC) plan!

9 What does an SPCC Plan look like? The plan must be well thought out and prepared in accordance with good engineering practices In many situations, the plan must be certified by a professional engineer Details of the plan must show the information that follows

10 TABLE OF CONTENTS SECTION DESCRIPTION SPCC PLAN One Plan Certification Two Facility Information Three Emergency Spill Procedures** Four Procedures on Fires/Catastrophic Occurrences Five Oil Handling and Spill Prevention Procedures Six Inspections Seven Staff Training Figures Figure 1: Street Map with Spill Containment/Recovery Points Figure 2: Aerial of Spill Containment/Recovery Points Attachments Appendix A: Spill Documentation Form Appendix B: Spill Response Equipment List Appendix C: Spill Prevention, Control and Countermeasures Training Log Appendix D: Storm Water Drainage Record Appendix E: Monthly Inspection and Recording Form Appendix F: Certification of the Applicability of Substantial Harm Criteria B. SPILL EQUIPMENT DEPLOYMENT PLAN I. Equipment Locations, Distance Downstream, Directions & Equipment Specifications II. Spill Containment Point Maps (Street & Aerial Maps) III. Individual Spill Containment Point Photoplates (C-1 through C-6) IV. Spill Kit Specifications

11 SPCC Plan Details The plan should detail the location of the facility Streams, ponds, lakes or rivers which may be impacted by a release from the facility must be identified Actions which will be taken to PREVENT the release or in the event of a release, how the company will attempt to CONTROL the release and the response actions which will be taken

12 SPCC Plan Details Location of the facility Maps should locate the facility and show waterways, streams, rivers and/or lakes Access for the facility as well as containment points needs to be shown with reference to the facility

13 SPCC Plan Detail Facility information Operations of the facility should be included in the plan Hours Shipping/receiving hours Location of the storage tank or tanks Include loading/unloading locations Containment dike

14 SPCC Plan Detail Facility personnel responsible for spill response / control Identify key facility personnel Provide contact numbers Office Home Cell

15 SPCC Plan Detail Details regarding stored products Identify the storage tanks/vessels Specify tank sizes Denote location of the units Indicate products stored in the tanks Provide information regarding the containment of the products and practices to control releases

16 SPCC Plan Detail Emergency Response Emergency response procedures need to be shown in the plan Response supplies (if facility personnel perform response activities) need to be identified Appropriate response agencies / contacts should be listed for easy reference

17 SPCC Plan Detail Inspection schedule Weekly inspections of tanks/valves need to occur looking for leaks or indications of failures Tank inspections must be carried out in accordance with established regulations Inspection of containment points verifying the access should be made periodically

18 SPCC Plan Detail Additional information Along with previously listed information Spill reporting forms Spill response information Training logs Inspection logs

19 SPCC Containment Points Containment points Release containments points need to be identified starting from the tank/vessel/unloading areas and continuing downstream Detailed directions to each of the containment points needs to be included Containment materials which can be used at each location are recommended in the details on the locations

20 SPCC Plan Implementation The implementation time for a plan is shown in the table below A facility (other than a farm) starting operation... On or before August 16, 2002 After August 16, 2002 through July 1, 2009 After July 1, 2009 Must... Maintain its existing Plan Amend and implement the Plan no later than July 1, 2009 Prepare and implement a Plan no later than July 1, 2009 Prepare and implement a Plan before beginning operations

21 SPCC Plan Implementation Once the plan has been prepared, facility personnel need to be trained in it s content and intent Spill response drills should be conducted to familiarize personnel in the use of the equipment and location of the containment points (if the facility maintains a spill response team) The plan should be reviewed and updated yearly and at least every 5 years reviewed and recertified unless facility changes occur before that time

22 SPCC Plan The SPCC Plan is intended for two purposes To promote prevention of spills and releases through training and early detection of problems Make personnel aware of spill response procedures and points where containment can be placed The plan also provides responders to a facility and a guide for spill containment and accessibility to the locations

23 SPCC Plan The SPCC Plan is a living document that must change with the facility Modifications through upgrades to a facility or changes in the process must be incorporated in the plan

24 Questions

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