If your facility is required to have a Facility Response Plan under SPCC regulations (40 CFR 112,) you’re probably familiar with the term “worst case scenario discharge.”
Chances are, you’ve already done a hazard evaluation and created lots of discharge scenarios, lists, and training modules (if not – better get moving: the deadline is November 10th… I’m sorry, but you aren’t eligible for the one-year extension.)
Because the main focus of Facility Response Plans is on “worst case” discharges, a topic that can sometimes get overlooked is the requirement to also plan for small to medium sized discharges.
According to the National Response Center, most discharges are less than 100 gallons, which makes preparing for small spills just as important as planning for “the big one.”
We’ve talked to a lot of customers who are creating, reviewing or modifying their response plans, and a common question is “how big of a spill kit do I need?” We even recently had a call from a customer who had just gotten off the phone with EPA and was really frustrated because they wouldn’t tell her how many spill kits she needed or what products should be in them.
Could that be right? Why couldn’t EPA tell her how many spill kits she needs? After all, she did know her worst case scenario discharge.
Just like other portions of the SPCC rule, the EPA specifically created flexibility in this area to allow facilities to determine what will best meet their particular needs. That’s why there was no hard, fast number of absorbent booms, bales of mat or any other “list” that the EPA could reference to answer this question.
Spill kits are just one of many tools that can be used to comply with the requirement to have “emergency response equipment” as part of your Facility Response Plan.
So, how many spill kits do you need, and where should you put them?
The first question we usually ask customers is how big of spill they can have at their facility (or in EPA terms, what is the “worst case scenario.”) But, that doesn’t tell the whole story.
Barring natural and man-made disasters, discharges most commonly happen when oil is being transferred, and spills are usually less than “worst case” levels. Data from the National Response Center helps to confirm this: most spills are less than 100 gallons.
Knowing this, it makes sense to put spill kits in areas where oil is transferred, and in areas where spills are likely to happen. Receiving docks, waste collection areas, processing areas, areas where oil is pumped from drums or totes, outdoor storage areas, and fleet maintenance areas are all good areas to consider for spill kits.
Next, consider the size needed in each area. Instead of looking at the overall “worst case” scenario, consider what is likely to happen in a given area. For example, if you’re pumping oil from a 55-gallon drum that is stored on a containment pallet into a five gallon bucket, you could create a “worst case” scenario for that area that would involve a full-drum failure that somehow missed the containment pallet.
However, it is far more likely that a spill in this area would involve someone tipping the five gallon bucket – so a spill kit that absorbs five gallons may be an appropriate choice for that particular area (especially if other kits can be accessed and brought to the area quickly to address “worst case” issues.)
For loading docks, consider the types of containers that commonly arrive: are they five gallon pails? Drums? Totes? If the biggest container is a 55-gallon drum, it’s reasonable to plan for a 55-gallon spill on the dock. You can follow this logic throughout a facility to address “small” spill needs.
So, back to “the big one.” If you have a 10,000 gallon, outdoor, above-ground storage tank – which spill kit should you choose?
We’ve found our large and extra large response carts to be a good fit for these scenarios, when they are coupled with other response equipment like our Drainblocker® Drain Covers, absorbent booms, vacuum trucks and other recovery equipment. They help get the spill under control while other equipment is being readied.
Still not sure? Give us a call. We’d be glad to walk you through possible solutions.
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