Even after more than a decade on the books, spill-prevention rules set forth by the U.S. Environmental Protection Agency (EPA) for aboveground storage tanks still lead to confusion on construction sites. With the pace of construction continuing to increase, and as labor shortages persist in hampering projects, it's important to remember the basics for compiling a Spill Prevention, Control and Countermeasure (SPCC) Plan.
The stakes remain high. Violations can be punishable by fines amounting to thousands of dollars per violation, per day. Lacking a plan could lead to a cease-work order, or — if a spill occurs — leave a site with preventable environmental damage, weeks of additional downtime and significant cleanup costs.
The SPCC rules apply to construction sites with more than 1,320 gallons of oil stored aboveground, in tanks or containers with capacities of at least 55 gallons per 40 Code of Federal Regulations (CFR) 112.
To comply, a site must:
- Provide appropriately sized secondary containment for storage tanks and drum and tote storage areas capable of holding the largest container in the containment area plus a 25-year, 24-hour storm event.
- Provide general secondary containment for truck transfer areas; spill response equipment can be used as an active containment measure for these transfer areas. It should be noted that most construction sites wouldn’t have loading/unloading truck racks that would fall under the requirements of 40 CFR 112.7(h), but truck transfer areas do need containment for the most likely spill scenario from the transfer operation per 40 CFR 112.7(c).
- Supply spill kits on-site in an accessible location for immediate release response.
- Mandate comprehensive training on the SPCC Plan for all oil-handling personnel working on-site at the time of employment and on an annual basis thereafter.
- Conduct monthly inspections of storage tanks, drums, oil-filled equipment and truck transfer areas to verify tank and secondary containment conditions.
- Drain stormwater from containment areas after rainfall events. Prior to draining stormwater, the water needs to be inspected for a sheen and this inspection must be documented.
Furthermore, it is essential to keep the SPCC Plan up to date with any changes in oil storage or containers of 55 gallons or larger. Construction sites commonly face difficulties in keeping track of these alterations due to the ever-changing nature of each work environment. Utilizing modern technology, such as tablets with specific software, can be an effective and easy way to keep oil inventory up to date to comply with SPCC regulations.
Developing and following an SPCC program is critical to many industries for avoiding public health hazards and preventing environmental crises.
