The New SPCC Rule Incorporates Industry Standards and Best Practices

Disclaimer The Inspectioneering Journal does not warrant the accuracy or appropriateness of recommendations made in this article. It is the responsibility of the reader to thoroughly investigate references to codes and standards and their applicability and efficacy to their individual situations. The views presented here are strictly those of the author and do not necessarily represent those of API or of any other organization. The Spills Prevention Control and Countermeasures Plan (SPCC) is a requirement of the Oil Pollution Prevention Regulation 40 CFR112 promulgated under authority of the Clean Water Act. Introduction The purpose of the new SPCC rule is two-fold; i.e. to prevent oil spills from occurring and to respond to them if they do occur. We believe that few will argue that prevention is far better and less costly than response in general. The focus of this paper is to highlight how the new SPCC invokes existing industry standards as a requirement for implementation at all covered facilities in an effort to prevent spills. In particular, we focus on the most important industry standards that are required to prevent spills from occurring in existing facilities. Since the SPCC rule does not specifically identify any required standards the task of figuring out which standards are applicable and must be implemented is a challenging one. There are at least a hundred industry standards related to tanks and terminal facilities. One purpose here is to help the reader narrow down the broad field of standards to the "critical few" that should form the core standards for incorporation into the SPCC Plan for most tank facilities. It is the intent to show and explain not only how the "pruning process" works but also which tank standards are the "critical few" remaining after the pruning exercise. A caveat is in order here. While we say "most important" or "critical few" we do not mean to minimize the importance of all relevant standards, only to state that those we mention are directly of most importance to the person(s) responsible for compliance.