Large or small, oil spills can endanger public health, wildlife, natural resources, drinking water, your reputation, and our economy. If you own a business, having an Oil Spill Prevention, Control, and Countermeasure (SPCC) Plan and/or a Facility Response Plan (FRP) can help. In this blog, we’ll unwrap exactly what goes into SPCCs and FRPs, who needs them, and why prevention is your best defense against an oil spill.
What are Oil SPCCs and FRPs?
The United States Environmental Protection Agency (EPA) has a goal to “prevent, prepare for, and respond to oil spills that occur in and around inland waters of the United States.” To achieve this, the EPA has established an oil spill prevention program that includes SPCC and FRP rules.
The intent of the Oil SPCC rule is to prevent oil from reaching navigable waters and shorelines and to contain oil discharges for many oil storage facilities based upon volume stored. The corresponding FRP rule requires certain facilities with an even higher volume of oil storage to submit response plans and prepare to respond to worst-case oil discharges or threats thereof.
Does your facility fall under the Oil SPCC rule?
Facilities subject to the Oil SPCC rule must develop and implement SPCC Plans and establish corresponding procedures, methods, and equipment requirements. Under EPA’s definition, if the total capacity of aboveground oil storage containers exceeds 1,320 gallons (with some exceptions, such as not including containers that are less than 55 gallons), an SPCC Plan is required.
Bulk oil storage facilities aren’t the only facilities that commonly need SPCC Plans. The following sites often have enough oil storage to exceed these thresholds, including common heating or waste oil tanks, and these are only some of the examples.
- Vehicle maintenance garages
- Manufacturing facilities
- Schools and public works facilities
- Facilities with diesel-powered emergency generators
- Fuel truck parking areas
- Car dealers
Creating an Oil SPCC Plan
Under certain conditions, people can draft their own SPCC Plans using resources on the EPA website, and St.Germain can ensure that our clients’ plans are complete and actionable. But many other facilities will require that the SPCC Plan be certified by a Professional Engineer and St.Germain can provide that service as well.
Each plan includes:
- A thorough assessment and identification of the facility, its buildings, and its operations
- A general summary of the facility’s oil storage
- A detailed breakdown of oil containers that exceed EPA thresholds
- An analysis of on-site tanks (including recommendations for how to handle single- vs. double-walled tanks and corresponding overflow protections).
- Identification of where oil would flow from a facility (including in a worst-case scenario), and where containment equipment should be positioned.
- A clear review of inspection and notification requirements
- Information on state-specific requirements
Do you also need a Facility Response Plan (FRP)?
The FRP rule falls under the legal authority of the Clean Water Act (administered by the EPA) and two Codes of Federal Regulations (40 CFR 112.20 and 40 CFR 112.21 ).
The rule is based upon whether a facility could cause “substantial harm” to the environment. EPA defines a facility that could cause substantial harm as one that:
Has a total oil storage capacity greater than or equal to 42,000 gallons and it transfers oil over water to/from vessels; or Has a total oil storage capacity greater than or equal to 1 million gallons and meets one of the following conditions:
a. Does not have sufficient secondary containment for each aboveground storage area.
b. Is located at a distance such that a discharge from the facility could cause “injury” to fish, wildlife, and sensitive environments.
c. Is located at a distance such that a discharge from the facility would shut down a public drinking water intake.
d. Has had, within the past five years, a reportable discharge greater than or equal to 10,000 gallons.
Typical facilities needing an FRP include large bulk oil facilities and marine oil terminals. If you’re looking for help with your FRP, the EPA’s Facility Response Planning Compliance Assistance Guide is a good starting point.
What comes after an oil spill?
While oil spills greatly vary in size and impact, we can provide some general guidance that is typical to many facilities.
After an oil spill, the first step is notification. In Maine, you need to call the Maine Department of Environmental Protection (DEP); and depending on the type of spill (especially if it’s left the site), you may also need to contact the EPA or Coast Guard if the spill is to navigable waters or has the potential to get there. In Maine, any amount of oil spilled is reportable to DEP; don’t forget that reporting requirements can vary greatly from state to state.
Many facilities rely on St.Germain to provide guidance on spill reporting and corrective actions. For example, if it’s a small spill and they’ve already contacted the DEP and used Speedy Dry absorbing granular material, we’ll confirm they are taking the right actions and walk them through any next steps.
If there is a significant spill outside, we will discuss remediation requirements like soil removal and continued monitoring.
No SPCC or FRP Plan required?
Even if your facility is not subject to SPCC or FRP rules, there are steps every facility should take to prevent oil spills from threatening the health of workers or the safety of our land and waters. Examples include storing drums on spill pallets, covering storm drains during fuel transfer operations, and maintaining vehicles to reduce or eliminate oil leaks.
Here are two case studies worth checking out:
When proactivity is the best protection
When you have a strong SPCC or FRP plan in place, you are taking the most important step to actively prevent an oil spill.
At St.Germain, our team helps prevent spills, so you can focus on running your business. We have a full understanding of the rules and how they are enfoced by regulatory agencies, and our engineering staff can design upgrades to your facility to improve operations – making it easier to comply with these regulations.
If you think your facility needs or could benefit from an Oil SPCC or FRP – or if you just have questions – we’d love to speak with you. Call us at (207) 591-7000 to learn more.