Here are nine things you need to keep in mind about the Spill Prevention Control and Countermeasure Plan – commonly referred to as the SPCC Plan.
1. If you have more than 1320 gallons of oil (any kind of oil) and you have the potential to impact navigable waters of the United States, you must prepare an SPCC plan. For example, if your facility is anywhere close to a storm water drain, you have the potential to impact navigable waters.
2. Recent changes to the EPA regulations require you to only count containers that are 55 gallons or larger in capacities towards the 1320 gallons threshold.
3. Plant management must sign its Plan indicating it is prepared to commit financial resources to implement the plan. If your plan is not signed by management, you do not have a plan. EPA inspectors will always look for the signature.
4. You can do self-certification – without the signature of a professional Engineer – if you have less than ten thousand gallons onsite and you have not spilled more than a thousand gallons within 12 months in the last 3 years.
5. You must have an SPCC plan if you store more than 42000 gallons of oil in underground storage tanks.
6. SPCC plans must be implemented by July 1, 2009.
7. You must have secondary containment for your oil storage area. Containment can take the form of a dike, berm, or natural contour. The idea is to contain any spilled oil and keep it from reaching navigable waters.
8. Do not count oils that you do not own or control For example, do not count transformer oils in a substation on your property IF you are neither the owner nor operator of that substation.
9. Keep your plan simple and do what you say you are going to do. Never make commitment that you cannot keep. EPA inspectors will always look for evidence of implementation. For example, if you say in your plan you are going to do weekly inspection of your facility, the EPA inspector will be looking for a weekly inspection checklist from you.