You take pride in your business. You work hard to make it efficient, productive, and profitable. Who has time for oil spill prevention and planning? Well, maybe you when a single quart of oil creates a two-acre slick (that’s almost three football fields) on a body of water’s surface, and a whole heap of environmental compliance headaches including $10,000s/day fines and imprisonment—in the worst instances—along with it. Oil planning enables you to be prepared, which ultimately saves you time and money … oh, and from the unwanted environmental-protection attention of regulators, concerned citizens and watchdog groups. Think of pre-planning as insurance, and you can develop and implement your own independent, oil-pollution prevention plan. If you have the capacity to store more than 1,320 gallons of oil above ground, you are required to prepare a plan to prevent oil spills including contingencies for responding to large spills. This includes gasoline, diesel fuel, motor oils, even vegetable/mineral oils. Inventories should, for example, only include containers greater than 55 gallons, and should not include any permanently closed containers, motive power containers or containers used exclusively for wastewater treatment. Such a plan is called a Spill Prevention, Control and Countermeasure (SPCC) plan. While required by the Federal Government, creation of an SPCC plan does not need to be overwhelming, and—when properly executed—does not need to consume a significant amount of your time or resources. The purpose of an oil plan is to evaluate your facility and predict where and how an oil spill could occur that could potentially reach waters off your property, and then take measures to prevent it from happening. Generally, achieving compliance is simple. You complete an inventory, prepare a plan, train employees, complete periodic inspections, and manage the oil storage and handling practices. Think simple. For example, are there oil spill supplies, is there sufficient containment, is the necessary equipment maintained, is there appropriate housekeeping (no exposed containers etc.)? Provided your total aggregate storage capacity is less than 10,000 gallons, you do not need a certified professional engineer to approve/stamp your plans. There are template, fill-in-the-blank type plans available from the United States Environmental Protection Agency (USEPA) to kick-start the process. Being prepared will bring peace of mind knowing that this important facet is covered and compliance can be demonstrated with federal, state and local oil and storm water requirements. Again, the best place to start is USEPA’s oil spill website at https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations, which provides applicability information, template plans, and guidance for preventing oil spills and, of course, what to do in the event you do have a spill. Feel free to contact me with any questions at (419) 305-3916 or leave them in the comments section below. Shara Dine Dine Comply, Inc.
Shara Dine is an environmental and safety specialist with over 25 years of environmental experience, and the founder of Dine Comply, Inc. (www.DineComply.com). The company advises clients and provides affordable, achievable solutions to environmental and safety compliance issues.
