Does your Field Services business need an SPCC Plan?

In this edition of the "Regular-atory Compliance" newsletter, we'll cover the basics of an important but often overlooked environmental plan - the Spill Prevention, Control, and Countermeasure (SPCC) Plan.

What is an SPCC Plan?

An SPCC Plan is a documented plan required by the U.S. Environmental Protection Agency (EPA) that outlines procedures, methods, and equipment to prevent the discharge of oil from non-transportation-related onshore and offshore facilities into navigable waters or adjoining shorelines.

Who Needs an SPCC Plan?

Facilities with an aggregate aboveground oil storage capacity greater than 1,320 U.S. gallons or a completely buried storage capacity greater than 42,000 U.S. gallons are required to have an SPCC Plan. This includes oil storage containers like tanks, drums, mobile/portable tanks, and certain truck-mounted tanks.

Key Elements of an SPCC Plan

Here are some of the main components an SPCC Plan should address:

• Operating procedures to prevent oil spills
• Control measures like secondary containment to prevent spills from reaching navigable waters
• Countermeasures like how to contain, clean up, and mitigate effects of an oil spill
• Methods for disposal of recovered materials after a spill incident
• Contact list and notification procedures for reporting a spill
• Inspections, tests, and records required for SPCC compliance
• Personnel training requirements related to the operation and maintenance of equipment

I have a Field Services company who does construction, fabrication, and maintenance for the oilfield. Do I need an SPCC Plan?

To look at this possible SPCC scenario, consider the field services company has:

• One 1,000 gallon double-walled lube oil storage tank
• Ten 275 gallon tote containers for storing used oil
• Four 550 gallon tanks for waste oil storage

Given the total aboveground oil storage exceeds 1,320 gallons, this company would likely need an SPCC Plan documenting spill prevention measures like secondary containment, inspection procedures, spill response actions, and other required elements.

Disclaimer: this is not legal advice and should not be construed as such.

?? Nathan Hammer and TrueComply AI 2024-present. All rights reserved.