Spill Prevention Control and Countermeasure

 General Description

As we know, oil spills can cause horrific impact to human health, the environment and the economy. The Spill Prevention Control and Countermeasure rule was promulgated under EPA’s Clean Water Act in 1974. The goal is to help facilities containing oil sources to prevent discharges into navigable waterways. The rule may be found in 40 CFR 112.

 Under SPCC, “oil” is very widely defined and includes, but is not limited to, petroleum, fuel oil, oil refuse and sludge, animal fats, oils or greases, vegetable oils and greases and other oils and greases including synthetic and mineral oils.

A facility is subject to SPCC and required to prepare and implement an SPCC plan if it has an aggregate aboveground capacity greater than 1320 gallons in containers 55-gallons or greater or an underground capacity greater than 42,000 gallons and there is a reasonable expectation of a discharge into a navigable waterway or adjoining shoreline.

 Plans must be reviewed and amended every five years or when facility information (personnel, oil sources, etc.) change.

 Elements of an SPCC plan include:

• Facility description and diagram
• Discharge calculations
• Secondary containment
• Likely spill path
• Site security
• Facility Inspections
• Container requirements
• Transfer procedures and equipment
• Training and recordkeeping requirements
• Management approval and plan certification

University of Wisconsin institutions utilize a state contract with a professional engineering firm to prepare and update facility SPCC plans. University of Wisconsin System employees may click here for details.

General regulatory citations and referenced standards

40 CFR 112

EPA SPCC Page

SPCC Guidance for Regional Inspectors

Training requirements

40 CFR Part 112.7(f) states "(1) At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan.

 (2) Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management.

  (3) Schedule and conduct discharge prevention briefings for your oil-handling personnel at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges as described in 40 CFR Part 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures."

Training should include understanding SPCC regulations and the facility's plan; operating procedures that prevent oil spills; familiarity with the control measures that are in place to prevent oil spills reaching navigable waters; familiarity with emergency response procedures and mobilization of key personnel; awareness of evacuation routes and procedures; and reporting and record-keeping requirements.

Department of Safety and Professional Services

SPS 310.440(3) (inserted below) requires periodic inspections of shop-built AST (most but not all ASTs) by operators no later than February 2013. The requirement is very similar to the Federal EPA SPCC regulation.  The difference is that SPS 310.440(3)(a)b excludes tanks less than 1,100 gallon capacity; whereas the SPCC rule applies to any size tank when the capacity aggregate for the site exceeds 1320 gallons.

On the tank program Internet forms web page are links to three (3) documents that have been developed for this AST operator inspection and recordkeeping requirement. The forms are in pdf interactive format so they can be filled out via a PC or field laptop. A template form can be developed by the respective company and respective tank information and saved electronically as a company specific template if the company has the proper Adobe software. There is not a requirement that these forms be used, however the operator needs to have a mechanism to demonstrate that the inspections were performed.  Inspectors have discretion in how they address operator periodic inspection compliance. If the facility has a history of good tank system management and dispensing housekeeping practices the inspector may elect to not ask to see records for verification of the periodic inspections; although inspectors should be reviewing documentation of required functionality tests.

DSPS Tank Program Forms Web Page:

http://dsps.wi.gov/er/ER-BST-FM-SPS310Forms.html

Tank Data Sheet to record the respective AST attributes.

http://dsps.wi.gov/er/pdf/bst/Forms_FM/ER-BST-FM-AST_DataRecord.pdf

Monthly AST inspection record:

http://dsps.wi.gov/er/pdf/bst/Forms_FM/ER-BST-FM-10897STI_SP001Monthly.pdf

Annual AST inspection record:

http://dsps.wi.gov/er/pdf/bst/Forms_FM/ER-BST-Fm-10898STI_SP001Annual.pdf

(3) Inspection of shop-built metallic aboveground storage tanks.  (a)  1.  The owner or operator of all shop-built metallic aboveground fixed storage tanks shall have the tanks inspected in accordance with STI SP001, except as provided in subd. 2.

 Other resources

UW-Milwaukee SPCC Page

EPA SPCC "Blue Book"

EPA SPCC 101

EPA Clarification Letter

Tucson Electric Power Company Presentation