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Effective SPCC Plan for Oil Storage Facilities - Ensuring Compliance and Prevention

Get a comprehensive overview of SPCC requirements and guidelines for facilities storing oil or oil products aboveground. Learn about qualified facilities, the need for a P.E. signed plan, and the importance of preventing spills. Avoid common mistakes and ensure your SPCC plan is thorough and accurate with this informative guide.

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Effective SPCC Plan for Oil Storage Facilities - Ensuring Compliance and Prevention

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  1. A Spill Plan that Works Michelle Barnett, P.E.

  2. SPCC Overview SPCCs • Reference 40 CFR 112 (SPCC & FRP) • Who must have a plan? • Facilities storing >1,320 gallons of oil or oil products aboveground • >42,000 gallons in buried storage • What is a Qualified Facility (Can I self-certify?) • <5,000 gallons in a single aboveground storage container, • <10,000 gallons aggregate aboveground storage • No single release in a year >1,000 gallons • No two releases in a year >42 gallons • Do I need a P.E. signed plan? • >5,000 gallons in single tank or >10,000 gallons overall • History of spills

  3. Ensuring you don’t get a good SPCC Plan • Don’t read it • Don’t ask “Is this information correct?” “Is this reasonable?” “How will we implement this?

  4. Features of a Bad Plan: Incorrect Information Items that are commonly wrong or missed: • Incorrect contacts • County, fire department or other agencies referenced • Emergency and Pollution Prevention Team Contacts • Poorly or incorrectly described site • Site Map does not show all storage locations or Plan list all stored materials • Runoff pathways, nearby waterways or sensitive areas • Underground flowlines and location of spill kits are not included • Site boundaries and stormwater outfalls incorrect • Training • Plan provides for training of too many or too few staff All personnel > All applicable personnel > only Pollution Prevention Team • Does not indicate when or how often personnel will be trained • Are subcontractors to be trained?

  5. Features of a Bad Plan: Layers of Reference “Inspections will be completed in accordance with Section 2.7(d)”… Section 2.7(d) states “Inspection shall be carried out on the schedule provided in Appendix H” Appendix H states “Inspections will be conducted to comply with 40 CFR Subpart B 112.7.” A good plan doesn’t make you work to find the information you need to be compliant. • Electronic documents with hyperlinks • Paper documents that include relevant information where its needed

  6. Features of a Bad Plan: The Impossible Inspection “Each container shall be inspected and the record of inspection recorded on the inspection form and the container inspection record.”

  7. Features of a Bad Plan: The Paper Avalanche “Each container shall be inspected and the record of inspection recorded on the inspection form.”

  8. Compliance Solutions that Work Michelle Barnett, P.E. 5100 East Skelly Drive, Suite 450 Tulsa, Oklahoma 74135 918-665-7693 mbarnett@enercon.com www.enercon.com

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