Veteran Owned and Operated
The Spill Prevention, Control and Countermeasure (SPCC) Plan
If your facility has the capacity to store more than 1,320 gallons of oil substances in tanks or 55-gallon drums above ground or 42,000 gallons in tanks below ground and oil-filled equipment, it is likely in Michigan that you need a SPCC plan according to the Federal Regulations. A facility that stores, processes, refines, uses or consumes oil and is non-transportation related is potentially subject to the SPCC rule. The reason for this is that if there is a spill at your facility the navigable waters and shoreline could be endangered. Even a ditch leading to a nearby stream is of consequence.
The kinds of oils covered by the regulations include synthetic oils, petroleum and refined products such as mineral spirits, gasoline, diesel fuel, vegetable oils, animal fats and fluids but does exclude certain substances such as milk.
As required in Title 40 Part 112 of the Code of Federal Regulations (40 CFR 112), the SPCC Plan describes equipment, workforce, procedures, including record keeping, training, control including containment and provides adequate countermeasures to the discharge of oil. If there is a release of oil or certain other materials then there is release reporting that is necessary including that related to Michigan Part 5 rules of Michigan Act 451. Further, your plans have to be reviewed every five years.
There have been amendments and revisions to the Federal Regulations that may require that your plan be updated as soon as possible.
Clarification and changes in requirements include:
- Updating of criteria used to determine who must prepare a SPCC plan.
- Above ground storage tanks and underground piping must be tested periodically.
- Additional requirements for corrosion protection for underground piping.
- Increase in requirements for design, performance and the Professional Engineer (PE) certification of secondary containment systems.
- Clarification of requirements for certain mobile facilities to prepare SPCC plans.
- The owner's responsibility concerning training and implementation of the plan.
- Enhanced storm water management and record keeping requirements.
- Enhanced requirements for routine facility inspections and record keeping.
- Changes in training requirements for employees that handle petroleum products.
- Changes of requirements for the PE's role in SPCC Plan preparation and certification
In certain cases where your facility is not a bulk oil facility it may be advantageous or necessary for the facility to prepare a Pollution Incident Prevention Plan (PIPP) per Part 5 that is updated every there years. This plan must be submitted and certified to the State of Michigan whereas the SPCC Plan does not have to be submitted to the EPA. There are other related environmental plans that might meet your needs such as an Integrated Contingency Plan and a Facility Response Plan.
Service Environmental Engineering has prepared SPCC Plans for a range of facilities from bulk petroleum facilities to foundries and is ready to assist you to determine if you meet the requirements and prepare or help you prepare an SPCC Plan. Again, there must be signed management approval and certification of the plan by a registered engineer.
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