If a release of any kind could potentially pollute navigable waterways, then your facility and company need a Spill Prevention, Control and Countermeasures (SPCC) plan. However, many facilities are not aware of what navigable waters include. If there is potential for a release into wetlands, drainage ditches, intermittent streams and even storm-sewer connections, then you still need an SPCC plan.
Experts keep finding the same mistakes over and over again. Most of the mistakes are due to lack of maintenance or monitoring containments. Below are common mistakes that could lead to costly fines.
Here are the top 6 Expensive Spill Plan Mistakes to Avoid
- Part of an SPCC plan includes drawings of totes, tanks and drums. Make sure to also include drawings of reservoirs, elevator rooms, oil-filled equipment and company-owned transformers.
- Inspect containment barriers and lining for cracks or tears. Comprised containment areas make facilities noncompliant.
- Invest in pest control. Make sure to monitor containment walls for chew marks or presence of pests. Having holes in containment walls leave facilities vulnerable to spills.
- High quantities of edible oils need to be addressed and contained on site. Tip: If food oils aren’t soluble, they need to be part of a spill plan.
- If you have above ground or underground tanks, you may not need an SPCC plan. However, it is best to always have documentation as to why you are not required to have a spill plan in the event you are visited by regulators.
- Always document employee training. Some facilities train employees but do not have any documentation. If a release happens, those facilities are asking for more fines without proof of training.
Have questions? SRP Environmental Consultants have extensive experience in producing and reviewing Spill Prevention Control and Countermeasures plans for companies of all sizes in different industries. We have eight convenient locations in Charlotte, Dallas, Denver, Honolulu, Long Beach, Midland, Shreveport and Pittsburgh. Contact SRP today at (866) 222-4972.