Even if your facility already has an SPCC plan in place, it doesn’t hurt to take it of the shelf and sneak a peek at it a little more often than the required 5-year interval spelled out in 40 CFR 112 to see if those good engineering practices that were listed so long ago are still relevant and viable.
When you think about all of the different technologies that have been developed over the past five or six years, it makes sense that EPA requires periodic plan reviews. It is very likely that there’s a new tool, form of spill containment, new types of spill berms, or some other gadget that wasn’t available ten years ago, and that might end up being a really good fit in your facility response plans.
What’s new in Countermeasures?
Let’s reflect for a moment on the last “C” in SPCC. It stands for “Countermeasures.” The elements in facility response plans document those countermeasures, listing what workers at the facility will use to contain, clean up and mitigate any oil spill that actually does reach navigable waters. Even if your facility doesn’t meet the criteria to be required to have a facility response plan, there still are some other spill containment and planning elements that need to be considered and documented with your SPCC plan.
Being able to provide spill containment is an essential plan element, and it goes a long way toward minimizing the effects of a discharge. Even if some oil does reach a drain and enter navigable waters, having portable spill berms, dikes or other devices to minimize the overall volume entering the water is still going to be a benefit to the overall clean-up effort.
In a guidance document on 40 CFR 112 issued to EPA Regional Inspectors, one of the elements that an inspector is tasked with looking for in a facility’s plan is whether or not they feel that the planning elements and control devices are adequate to control or mitigate an oil discharge.
Specifically, what’s new in Spill Berms?
Spill berms are a control device that gives facilities a lot of liberty for containment and diverting liquids. Years ago, spill berms were most often highly engineered products—most often made of concrete—that required several months and hundreds of drawings before installation. Now, there are other options—both active and passive—that can alleviate a lot of the headaches associated with stopping spills, without being an obstacle.
One example is our PIG® Build-A-Berm® Barrier. It comes in two, four and six-inch heights and is simple to install indoors or outdoors to provide active secondary spill containment around tanks, processing areas, storage bays or anything else that could leak. I actually had a call from a customer last week who has had one in place in a tank farm in Texas since 2004—and it’s still going strong; he just needed some new sealant because it was starting to crack in a few places and he wanted to renew the seal.
One of the neatest features of this product is that unlike hard, concrete berms, the foam core allows the product to be walked on or driven over, so you never lose or limit access to the area being contained.
If low-clearance vehicles are in use—here’s what else is new!
If traditional spill berms just won’t work—which is sometimes the case if tow motors or other vehicles with low clearance are common at your facility, our PIG® SPILLBLOCKER® Dikes are a great form of passive spill containment. The flexible polyurethane hugs flat surfaces, creating a seal that keeps liquids in check and out of sensitive areas. Like the PIG® Build-A-Berm® Barrier, it is also available in multiple heights to meet a variety of containment needs. It can be deployed proactively prior to fluid transfers, or reactively in response to a release that has just happened, making a versatile spill response tool.
Depending on the type of secondary containment needed, 40 CFR 112 does offer a lot of flexibility when choosing products or designs to fit your facility’s needs. With innovative products, you may no longer have to settle for concrete moats that don’t allow access. If you facility is expanding or changing processes, it might be time to consider new ways of containing them, too.
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