COVID-19 Impacts to Your SPCC Plans: Are Your Plans Up-to-Date?
The COVID-19 pandemic has impacted all industries to some degree over the past year. With offices shut down, and some workforces working remotely, many offices have been left vacant. At the beginning of the pandemic, food and beverage and consumer goods manufacturing facilities were temporarily shut down or production was significantly reduced. Restaurants and retail facilities were closed or transitioned to online ordering and pick-up. Only critically essential services and operations managed to stay open.
At many of these facilities, Aboveground Storage Tanks (ASTs) and/or Portable Containers (drums/totes) are used for oil or fuel storage critical to operations. If these facilities meet the criteria indicated below, then the facility must prepare and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan according to the Federal Oil Pollution Prevention regulation 40 CFR part 112.
Many of the facility changes brought about by the COVID-19 pandemic could affect the status of SPCC regulated tanks and containers. It is important that these changes, which could materially affect the facilities potential for discharge of oil, be captured in the facility SPCC Plan within the required timeframe.
The SPCC plan amendment must also include revisions to the facility’s SPCC diagram capturing the appropriate changes. The regulation states that you have to “describe the physical layout of the facility and include a facility diagram, which marks the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located. The diagram must include completely buried tanks, transfer stations, and connecting pipes. (40 CFR 112.7(a)(3)).”
The SPCC rule applies to facilities that:
- Have an aboveground oil storage capacity of 1,320 U.S. gallons or more (in containers which are 55 gallons or greater), or a completely buried oil storage capacity of 42,000 U.S. gallons or greater;
- Could reasonably be expected to discharge oil to navigable waters or adjoining shorelines in quantities that may be harmful; and
- Are non-transportation related.
You, as the owner/operator of a SPCC regulated facility, and as part of your associated SPCC Plan, “shall amend the SPCC Plan whenever there is a change, which materially affects the facility’s potential for discharge. Such amendments shall be prepared within six months, and implemented as soon as possible, but not later than six months following preparation of the amendment. (40 CFR 112.5(a)).
These ‘technical’ changes can include but are not limited to:
- New tank/container construction or reconstruction,
- Temporary containment area or change to containment,
- Tank/container decommissioning, dismantling or moving,
- Bringing an empty tank back online,
- Changes in bulk liquid products handled,
- Pipe or pipe way changes, and
- Updates to tank inspection or maintenance procedures
In addition, SPCC Regulations require that for facility changes of this ‘technical’ nature, the amended SPCC Plan must be certified by a licensed Professional Engineer (PE)(40 CFR Part 112.3(d)).
Oil Storage Changes That Should Be Considered
1. Change to Office/Emergency Generator Status:
Consider an office building which now sits vacant. Perhaps the emergency generators are no longer needed to maintain critical operations. If the generator fuel supply tanks are “out of service” or “permanently closed” then the SPCC plan must be amended. If a previously vacant office building is now being reopened and the emergency generator brought back online, or a generator has been resized or replaced due to change in operational need, this would trigger an SPCC Plan amendment.
2. Change to Cafeteria/Waste Grease Container:
Offices, large technology campuses, or factories will sometimes provide an onsite cafeteria for employees. With these cafeterias being closed due to COVID-19, the associated waste cooking grease containers may have been removed. Or perhaps a grease container previously removed is returned to the facility for reopening of cafeteria operations. In either case, the SPCC plan must be amended.
3. Change in Product Storage:
Several factories and food and beverage manufacturers retooled and changed operations during the pandemic to provide products that were in greater demand. This retooling may have required that a different oil product be stored at the facility. The change in product creates the need to update the SPCC plan.
“Out of Service” vs. “Permanently Closed” Tanks and Containers
A facility may determine that an oil storage tank is no longer needed and declare the tank to be “Out of Service” and no longer in use. However, SPCC regulation requires that an “Out of Service” tank still be included in SPCC planning and periodic inspections performed. To be able to remove an unused tank from the SPCC plan and inspection requirement, the tank must be rendered “permanently closed.” Only then can the container remain onsite at the facility but be removed from the SPCC plan.
From 40 CFR 112.2, permanently closed means any container for which:
- All liquid and sludge have been removed from each container and connecting line,
- All connecting lines and piping have been disconnected from the container and blanked off, all valves (except ventilation valves) have been closed and locked, and
- Conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure.
Don’t Forget Annual SPCC Training
SPCC Regulations require, “At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan. (40 CFR 112.7 (f)(1)).” This training must be completed annually. Due to COVID 19 related shut downs, this SPCC training may have lapsed, or changes in oil handling personnel due to layoff and rehiring may necessitate additional training.
The Benefits of Maintaining your SPCC Plan Current with Facility Changes
The COVID 19 Pandemic brought about many changes in business including labor forces working from home leaving offices vacant, shut down or retooling of manufacturing facilities, and closure of retail facilities. These closures as well as potential restart to operations could lead to changes with facility oil storage and handling which could impact the SPCC plan for that facility. It is an SPCC requirement to maintain a facility’s SPCC plan current with operating conditions. Therefore, owner/operators of SPCC regulated facilities that were impacted by the pandemic should take inventory of their oil storage operations to determine if their SPCC plan needs to be amended. Failure to maintain your SPCC plan to current facility oil storage operations can lead to regulatory violations of up to $25,000 per day per violation.
Antea Group can assist you in determining what changes may have occurred with oil storage and handling at your facility due to COVID 19 impacts by performing an Environmental or SPCC specific audit. If an SPCC plan amendment is warranted, Antea Group can assist with the plan revisions and ultimately Professional Engineer certifications for the SPCC plan. In addition, we can conduct SPCC Annual Trainings online or at your facility. These trainings are specifically tailored to your facility’s oil storage operations.
About Antea Group: Antea Group is an international engineering and environmental consulting firm specializing in full-service solutions in the fields of environment, infrastructure, urban planning, and water. By combining strategic thinking and multidisciplinary perspectives with technical expertise and pragmatic action, we do more than effectively solve client challenges; we deliver sustainable results for a better future. We serve clients ranging from global energy companies and manufacturers to national governments and local municipalities. Learn more at https://us.anteagroup.com.