Does Your Petroleum Facility Have a Spill Control and Countermeasures Plan?

Like many things that are monitored and governed by the U.S. Environmental Protection Agency (EPA) and by the Occupational Safety and Health Administration (OSHA), oil spill control and countermeasure plans are highly regulated by a web of complex requirements.


As the industry continues to evolve, the documents associated with spill prevention are frequently amended and updated as new areas of exploration and industry innovations raise new concerns.


When it comes to putting in place, or even updating, spill prevention plans, many businesses may find themselves jumping from one question to the next. Here is a brief overview to answer preliminary questions if you do not currently have an updated plan in place.


Who requires and regulates spill controls and countermeasures?


Following the Clean Water Act of 1972, regulations to the oil industry include careful consideration of any potential threats of oil spills a site poses.


Regulated by the EPA, a list of nearly PDFs can be found on their Laws and Regulations webpage that track the regulations and updates, from 1973 when the original Oil Pollution Prevention; Non-Transportation-Related Onshore and Offshore Facilities regulations were put in place, to the most recent update from 2010.


The original 1973 document required non-transportation-related facilities each owner or operator to:


· Have an aggregate storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons; and could reasonably be expected to discharge oil or hazardous chemicals in harmful quantities into navigable waters of the United States.


· Prepare an SPCC Plan. The plan is required to address the facility’s design, operation, and maintenance procedures established to prevent spills from occurring, as well as countermeasures to control, contain, clean up, and mitigate the effects of an oil spill that could affect navigable waters.


Why do you need assistance developing a spill control plan?


With limitations to profit in the form of fines, fees, and potential shutdowns, it is imperative that oil companies put in place or update spill control plans to establish compliance with all regulations.


Since there is no one-size-fits all plan (each plan must be specific to the facility), many businesses turn to certified professionals with experience and expertise to tailor a plan for their needs.


SRP Environmental’s spill prevention experts are experienced in:


1. The development of an SPCC plan

2. Site audits

3. Reviewing of facility records

4. Reviewing of regulatory records

5. SPCC Training

6. The Certification of plan by registered Professional Engineer

7. SPCC Modifications & Updates


At SRP Environmental, we know that unlike oil spill contingency plans that typically address spill cleanup measures after a spill has occurred, SPCC plans ensure that facilities put in place containment and other countermeasures that would prevent oil spills that could reach navigable waters.


Under EPA’s Oil Pollution Prevention regulation, facilities must detail and implement spill prevention and control measures in their SPCC Plans.


A spill contingency plan is required as part of the SPCC Plan if a facility is unable to provide secondary containment (e.g., berms surrounding the oil storage tank). In short, the plan must describe how you intend to operate your facility to prevent spills and what you will do to deal with them if they occur.


(For more information, visit our Spill Prevention Control and Countermeasures Compliance page.)


Of course, behind all of the business savvy and desire to be in compliance with EPA regulations lies the real reason for spill prevention planning.


Any American over the age of 30 finds that ghastly images of oil sodden ducks, birds, and seals still jump to mind when the words Exxon Valdez, are mentioned. Over two decades old, the 1989 environmental disaster is still fresh in our minds and is second only to the more recent BP spill of 2010.


No company owner, or even its lowliest part-time worker, wants to be associated with an environmental disaster. Whether the potential damage would be done to a small local pond or the Gulf of Mexico, thorough compliance with EPA regulations can help to prevent such an event from ever occurring.


For more information from the experts at SRP Environmental, contact us today.