40 CFR Part 112, requires that certain facilities develop and implement oil spill prevention, control, and countermeasure, or SPCC Plans.
SPCC Plans ensure that facilities establish sufficient containment and/or other applicable countermeasures to reduce the potential for oil spills to reach navigable waters. However, oil spills typically result from accidents or human error, which can occur at any place, time, or location. SPCC plans can often be confused with oil spill contingency plans, which typically address response measures after a spill has occurred.
Once a spill occurs, the best approach for containing and controlling the spill is to respond quickly and in a well-organized manner. According to the EPA, a contingency plan "looks at all the possibilities of what could go wrong and, “contingent” upon actual events, has the contacts, resource lists, and strategies to assist in the response to the spill." A spill contingency plan is required as part of the SPCC Plan if a facility is unable to provide adequate secondary containment.
Elements of an SPCC Plan include:
- Professional Engineer Certification
- Discussion of conformance with federal regulations
- Facility description, plot plan, and contacts
- Potential spill volume and flow rates
- Inspections, tests and record keeping processes
- Personnel training requirements
- Loading/Unloading and transfer details
- Discharge prevention measures
- Security Measures
- Recovered material drainage and disposal methods
- Bulk Storage tanks details
- Secondary containment locations and volumes
- Discharge notification information and procedures
The Oil Spill Contingency Plan
Elements of a Contingency Plan include:
- Hazard identification
- Types of oils stored
- Transport details
- Extreme weather conditions
- Response equipment and personnel details
- Vulnerability analysis
- Identification of resources and communities potentially affected by a spill
- Risk assessment
- Comparing the hazard and the vulnerability for a specific site(s) to determine potential controls, prevention, and necessary repairs
- Response actions
- Description of actions required in the event of a spill.
Although "prevention is the best medicine", companies should investigate each spill to determine how future occurrences can be eliminated.