A few minutes during your monthly SPCC inspection could save you millions in potential fines. Here’s how to make the most of these required inspections.
Back in the summer of 2014, Duke Energy released 9,000 gallons of diesel fuel into the Ohio River from a power generating plant in New Richmond, Ohio. The incident caused an oil sheen 15 miles long and eventually resulted in a $1 million fine for a Clean Water Act violation. This doesn’t include the $1.2 million in cleanup efforts to recover “only a small portion” of the spilled diesel from the Ohio river.
It’s a nightmare scenario for anyone responsible for spill prevention control and countermeasure (SPCC) planning and implementation. But it’s also a reminder that we might save ourselves millions in just a few minutes during a monthly SPCC inspection.
What caused the Duke Energy incident? According to a release from the U.S. Attorney’s Office Southern District of Ohio:
“A Duke Energy operator transferring fuel from three 705,000-gallon capacity tanks ran the forwarding pump too long and over-filled the two 30,000-gallon capacity above-ground fuel tanks. Diesel fuel spilled from the tank overfill vents into a concrete secondary containment area. A valve on the secondary containment area had been improperly left open by other Duke employees, causing the spilled diesel fuel to escape the containment area and enter directly into the Ohio River.”
The open valve on that secondary containment area is what catches our attention most in this account. While we can’t always prevent human error, we can certainly do our best to be ready when it happens. A monthly SPCC inspection is a chance to make sure your systems and fail safes are all working as they should and potentially prevent your own costly fine.
If you’re new to SPCC planning, it’s a requirement by the U.S. Environmental Protection Agency (EPA) for any facility with more than 1,320 gallons of petroleum products (diesel, gasoline, oils, etc.) stored above ground. It encompasses all types of facilities from truck stops to manufacturers to municipalities. One of the requirements of the SPCC plan is to do a monthly inspection that includes inspecting stormwater, secondary containments around the tanks, and looking for any evidence of spills.
How do you make the most of these inspections? First, start with a complete and specific inspection checklist. It should include all areas of the site, including all oil storage areas and containment structures that need to be inspected. Then include specific tasks for each inspection area. Instead of “check the valve” try “check the valve in the secondary containment wall to see if it is closed and operating properly.”
Questions make good checklist items, too: Is Tank 1 showing any sign of leakage? Is the valve closed on the secondary containment for Tank 1? Is the secondary containment structure for Tank 1 showing any signs of deterioration? It might seem daunting to be this precise, but when the tasks are more specific, you’re more likely to catch issues. Don’t be afraid to double or triple the length of your inspection checklist to cover all necessary items. Thorough is better than facing a failure and, potentially, a fine.
Second, take the time to train any employees who will be conducting the monthly SPCC inspection. Give them all a copy of the checklist and physically walk them through a full-scale inspection. Show them what they’re checking for on each line of the checklist, describe how the structures should look, and describe signs of a leak or deterioration. Make time to answer any questions and show your team how to document and report any issues found during the inspection. Then outline the process for resolving those issues.
It’s also a good idea to make the routine as easy to follow as possible. Pick a certain day of the month (e.g. first Monday or final Friday). You might combine the SPCC inspection with other required inspections, such as stormwater inspections or general facility maintenance inspections for efficiency. Have a back-up person ready if the regular inspector happens to be out on the appointed day.
You might not always look forward to conducting a monthly SPCC, but remember, the minutes you spend checking those tanks and valves really could save you millions.
Check out our free, downloadable SPCC inspection checklist template here.
If you have questions about spill prevention control and countermeasure (SPCC) plans, please contact Judy Hessling at (513)792-6936.
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