What is a SPCC Plan Checklist?
According to the US Environmental Protection Agency (EPA), a Spill Prevention, Control, and Countermeasure (SPCC) plan aims to help organizations in preventing oil spills and controlling them when they do occur. SPCC regulations entail the implementation of certified SPCC plans by operators or owners of qualified facilities that store oil and petroleum products.
A SPCC checklist is a guide to create a spill prevention, control, and countermeasure program that focuses on the SPCC rule requirements and a template can be downloaded and completed manually or electronically. Of course, the template can also be customized based on your specific needs and is just a general guideline. The following is a sample checklist that features items used in onshore oil drilling and production:
- Sorbent materials
- Retention ponds
- Spill diversion ponds
- Curbing pans
- Gutters and drainage systems
- Sumps
- Booms, weirs, and barriers
In this article, you will learn more about:
1. The 5 Steps of an SPCC Inspection
2. Tips On How To Pass SPCC Inspections
3. The Digital Tool That Will Facilitate Creating SPCC Plan Checklists
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The 5 Steps of a SPCC Inspection
Before an inspection can be performed, owners or operators should be aware whether they need to adhere to the SPCC rule or not.
The SPCC should be followed by facilities that
- store, transport, or consume oil products like gasoline, diesel, lube, animal and vegetable fat, and more.
- keep more than 1,320 gallons of aboveground containers or 42,000 gallons of oil products in buried containers.
- are expected to empty oil products into navigable US waters and adjoining shorelines.
If you and your facility fit into one of these categories, you can expect an inspection to take place. As a general rule, inspections follow these 5 basic steps:
- An EPA inspector accesses your facility.
- There will be an opening conference between the inspector and the facility owners or operators. The assessor will show his credentials and certifications.
- The scope of the inspection will also be discussed and SPCC rules clarified during this meeting. The EPA inspector will only follow the SPCC checklist and will furthermore review records onsite.
- After the record and checklist review, the facility walkthrough takes places. The assessor will check pipings, tanks, transfer areas, loading racks, drainage controls, and safety measures that are in place. Photos will also be taken during the walkthrough for documentation.
- The last leg of the SPCC inspection is the closing conference with the facility operator and staff. The EPA inspector will present his observations and answer questions the facility might have. He will also present potential deficiencies and give recommendations on how to address those issues.
How to Pass the SPCC Inspections in 5 Steps
The SPCC regulations are performance-based and subjective. However, as long as you use good engineering practices and the following tips, you’ll be able to ace your inspection:
1. HAVE AN OIL-FILLED EQUIPMENT INTEGRITY TESTING
As mentioned, SPCC covers oil storage containers that are at least 55 gallons or more. Check if you have containers that are used only for oil storage or oil-filled equipment that holds more than 55 gallons of oil on your site. As they fall under SPCC rule, they might be subject to an inspection. Therefore it is important to make sure to check these oil storage containers for leaks, corrosion, damages, and functionality.
2. CONDUCT MONTHLY INSPECTIONS
It might be extra work for you but a regular monthly inspection will help you assess whether you are still in compliance with the SPCC inspection checklist or not. As a preventive measure regular check-ups will also ensure the general functionality of your storage equipment and containers independent of mandatory inspections.
3. BE AWARE OF YOUR SURROUNDINGS
The SPCC rules mention that a storage facility near navigable water and shorelines is subject to an inspection. Nearby in that case may also mean that you fall into this category if your facility is located near sewer systems, drainages, and ditches that might transport oil spills into navigable water.
Always check if pipes, floorings, and containers are free of leaks, cracks and damages where oil might seep into the ground.
If your storage facility conducts oil transfers, have spill kits and other general containment equipment at the ready since it will be easier and more rapid to clean oil spills immediately and prevent any damages. Here are some tips on how to clean an oil spill using the spill kit:
- Put safety glasses on
- Wear nitrile gloves
- Wear absorbent socks around drains and the spill itself
- Use absorbent pads and pillows to absorb the spill.
- After cleaning the spill, place the absorbent materials in a bag for disposal. Make sure it is tied tightly to contain the spill.
4. ENSURE CONTAINERS AND VALVES ARE TIGHTLY CLOSED
Make sure that valves and containers are tightly closed after each use and even when they are not in use. If the valves are opened, ensure that the oil released is properly contained.
5. LABEL EVERYTHING APPROPRIATELY
Labelling each container appropriately will help you stay in compliance. Most of all, however, consitently labelling everything will help you with keeping an inventory of what you have in your facility. It also informs workers what they are dealing with and makes them aware of the risks they are exposed to, leading to more cautiousness.
Some of the information you can include on the labels are:
- Tank capacity
- What kind of oil is inside the container
- Tank name and ID
- Applicable cards
Applicable cards could include other information like hazardous waste storage date, date of accumulation, and more.
Create SPCC Plan Checklists With A Checklist-Software
Organize your facilities and prevent and or adequately take care of oil leaks or spills with a digital SPCC checklist that reminds you of audits, ensures no elements are forgotten and protects your company and the environment at the same time.
Lumiform’s inspection app allows you to easily perform safety and maintenance audits online or offline or on the go from your smartphone or tablet. Create regular checklists and establish a SPCC plan with which you can easily collect data and ensure your facilities are prepared for potential oil leaks and spills.
