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SPCC Spill Prevention Control & Countermeasure Plans

SPCC Plan – Spill Plans – EPA  40 CFR 112 Requirements

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MANDATED LEGISLATION: The acceptance and necessity of SPCC plans, and general spill plans for all type of facilities which are related to the oil and gas and energy industry are now widely recognized. History of the world’s events of past oil spills, salt water contamination, and chemical spills which have spoiled our lands, creeks, rivers, lakes and navigable waters, and on to our oceans, were many times preventable. From simple SPCC spill plans for a single oil production facility to a refinery, or from an offshore drilling rig, oil transportation barge, a product pipe line to a bulk storage facility, all need and require a spill plans in order to protect our environment and navigable waters.

HISTORICAL BASIS
Before the advent of the EPA , oil and gas companies generally abided by self imposed rules and standard operating procedures which protected our lands and waters. Even when the custom of producing the flow back of new wells to open pits was an accepted practice, care and attention to the potential threat of a spill onto the land and creeks were recognized. We all have seen the scarred earth where salt water has stripped the soils, leaving lands unproductive for years, allowing for erosion to begin and cause even more damage. Yet, not all companies were concerned about oil spills or salt water contamination and felt it was acceptable to operate by bleeding water off of production tanks or dumping salt water along county roads, or upon the pastures to kill off undesirable vegetation.

Due to these operators the EPA has been able to enforce their mandated legislation to insure compliance by all producers and operators of oil & gas production wells, as well as all other service and energy related firms associated with all drilling and production.

EPA & SPCC
Consequently, the SPCC, Spill Prevention Control & Countermeasures Plans now regulates our industry and is enforced by the Environmental Protection Agency, EPA. These measures not only affect the oil and gas industry but all industries and firms which are responsible for the proper handling and disposal of fluids and gases which affect our environment. While the spill plans are the first line of defense to prevent the anticipated possibility of an oil or salt water spill, the SPCC plans go much farther to provide a means to monitor sites activities, provide training, retention of documents, and a readily available site diagram of the facility and the associated spill plan. Protection of the world’s environment is a major factor worldwide today by all energy firms. The EPA guidelines for SPCC plans are adaptable and can be used universally to adhere to good management practices. Accidents occur regardless of all the planning, and now the threat of terrorism, require a readiness level to be able to address any problem which arises.

COMPLIANCE REQUIRED From a period in 1973 with the beginning of the legislation and requirements of SPCC plans till today, the availability of information concerning the oil spills, and the SPCC plans have multiplied immensely. With the advent of the internet, the informational resources available for SPCC plans are only a click away from being completely informed of not only the SPCC regulations on the EPA’s website, but also all the vendors providing a spill plan service. The duplication of the rules and regulations are on every site. Links to the sites providing SPCC plan information are on this site.Today, the EPA is very active in ensuring compliance with their mandated regulations. In order to do so, due to the high number of facilities required to have SPCC plans, the use of helicopters allow them to

easily fly over your installation and visually determine if your tank battery is within compliance. Should lightning strike your facility, or you happen to have a fire or an unavoidable oil spill that is reported, then you will be asked to present at that time your SPCC plan and a copy of your annual lease inspection. The annual lease inspection provides documentation of the facility equipment. Should you not be able to produce a copy of your SPCC plan and annual lease inspection, the EPA will most assuredly fine the operator or producer.

An SPCC Plan should include the following information and should follow the sequence outlined below:

• Written descriptions of any spills occurring within the past year, corrective actions taken, and plans for preventing their reoccurrence.

• A prediction of the direction, rate of flow, and total quantity of oil that could be discharged where experience indicates a potential for equipment failure.

• A description of containment and/or diversionary structures or equipment to prevent discharged oil from reaching navigable waters. (For on-shore facilities, one of the following should be used as a minimum: dikes, berms, or retaining walls; curbing; culver ting, gutters, or other drainage systems; weirs, booms, or other barriers; spill diversion ponds; retention ponds; sorbent materials.)

• Where appropriate, a demonstration that containment and/or diversionary structures or equipment are not practical and a strong oil spill contingency plan and a written commitment of manpower, equipment, and materials to quickly control and remove spilled oil.

• A complete discussion of the spill prevention and control measures applicable to the facility and/or its operations.

The SPCC Plan should include a demonstration of management's approval and should be certified by a registered professional engineer.

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