ISO 14001 SPCC (Spill Prevention, Control and Countermeasure)

[Welty]

Has anyone written a SPCC (Spill, Prevention, Control and Countermeasure) plan? I have it about complete and was open to any suggestions or comments about things to look for. I am also going to be looking for an PE, if anyone knows a good one in Ohio.

Thanks,
LW

[Randy]

I've written quite a few. 1st thing you need to determine is "Do we really need one?" The second thing is "What can we change to keep from writing one?"

Just follow the regulatory guidelines.

[Welty]

Regulations state that any facility the has 1320 gallons or more needs to have an SPCC plan. We currently have a 550 gallon tank, 150 gallon tank and 20 presses that hold total of 1317 gallons. This is where the requirement has us. The press amount is enclosed in the press and is what is used to have it function. It is not a holding tank, but in the piping of the press. This is what put us over the limit.

Hopefully I am missing something.

I has told that all oil, even in use oil in a press has to be accounted for.

[Randy]

If you check the regulation you will find out that it is cumulative capacity, but that of a single tank that is indicated. Normally you only need to do an SPCC when you exceed 500 or 600 gallons in a tank.

If its 500 gallons, review your usage history of the material. You may be able to get by with a smaller tank. Or use 2 tanks of smaller size. If the limit is 600 gallons, you don't have to do anything.

With this amount of material you only need to have a good hazmat response based on 29CFR 1910.120 (IMHO)

Double check the law...you may be killing yourself for nothing. I can almost guarantee you that the amount limit for a SPCC is not cumulative.

I'll look too

[Randy]

Here's what I got from the EPA. I was partially correct.

In 1973, EPA issued the Oil Pollution Prevention Regulation, which is codified at 40 CFR Part 112 (PDF download, 576K, 72 pages) Abstract, to address the oil spill prevention provisions contained in the Clean Water Act of 1972. The regulation forms the basis of EPA's oil spill prevention, control, and countermeasures, or SPCC, program, which seeks to prevent oil spills from certain aboveground and underground storage tanks. In particular, the regulation applies to non-transportation-related facilities that:

* Have an aboveground storage capacity of more than 660 gallons in a single tank, an aggregate aboveground storage capacity of more than 1,320 gallons, or a total underground storage capacity of 42,000 gallons; and

* Could reasonably be expected to discharge oil in harmful quantities into navigable waters of the United States.


My recommendation would be to review what you do and why you do it. Reduce the amount of spillable material that you maintain. If you don't need it, get rid of it!

You'de be surprised what a process review will reveal and how potential impacts can be reduced.

I guess I've provided you with an Objective for an Aspect "Reduce the potential for spillage and the requirement for an SPCC" Now you come up with the Target

[kalehner]

I think Welty got it right. If they have 1320 gal onsite and have no SPCC they could be found in violation of 40 CFR part 112. It seems crazy but I believe that is how it works. This would be a big issue if they spill something into a navigable waterway and the Feds descend.

[Randy]

You're right Kevin, that's why I suggested a review of everything to see if there is a possibility to reduce what they maintain.