Common SPCC Findings
Posted on July 30, 2020
Top 5 SPCC Inspection Findings
Does your facility need a Spill Prevention Control & Countermeasure (SPCC) Plan? Do you house more than 1,320 gallons of oil in your facility? If so, the Environmental Protection Agency (EPA) requires an SPCC Plan in accordance with 40 CFR 112.
At Environmental 360, Inc. we create and audit SPCC Plans and provide inspections every day in facilities across the country. The top five most common deficiencies we see in facilities include: oil/water in containments, leaking pipes, labeling issues, corroded/dented containers, and exclusion of various types of oil from plans.
Oil/Water in Containments
It is common to observe oil or water in secondary containment structures. The EPA requires any oil accumulation from diked areas to be removed promptly. After large rain events, secondary containments can fill with water, reducing the available capacity of the containment to hold oil from a potential leak or spill.
Leaky hydraulic pipes are frequently observed during periodic SPCC inspections. These pipes are required to be fixed promptly but are often overlooked and continue to leak. This also causes the containments to fill with oil and can lead to more serious issues like system malfunction or loss of revenue.
OSHA’s Globally Harmonized System for Hazard Communication required facilities to label all tanks by June 1, 2016. Therefore, all oil containers should be labeled with their contents. We typically find containers that lack any labelling at all. Often, used oil containers are labeled with “waste oil” or “bad oil;” however, the EPA only accepts the phrase “used oil”.
Oil containers are required to be frequently inspected for corrosion and damage. Many times, these deficiencies are dismissed, and the condition of the tanks only worsen. Damaged tanks can leak or rupture over time leading to an unwanted oil discharge. 55-gallon drums are the most common container that we find with this deficiency.
Exclusion of Oil from Plans
Many facilities have more oil on-site than they realize. EPA’s definition of oil includes petroleum and non-petroleum oils. We provide SPCC Plan updates for many new clients and come across oil products that were previously missing. Chemicals like polymers, flocculants, and defoamers and even cooking grease all contain oil and are subject to the SPCC requirements. The Coast Guard has a lengthy list of all the petroleum and non-petroleum based oils. The safety data sheet for chemicals is not likely to list “oil” as an ingredient, so it is best to contact the chemical vendor and ask if any oils from the Coast Guard list are in the chemical.
Additionally, we have noticed oil-filled transformers are commonly missing from SPCC Plans. Oil-filled transformers typically contain a silicone base product and must be included in an SPCC Plan.
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