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SPCC Fun with Facility Diagrams!

SPCC
by Kelly Lagana
"One fundamental, required component of a compliant Spill Prevention, Control, and Countermeasure (SPCC) Plan is a description of the physical layout of the facility in a facility diagram."

According to EPA, the facility diagram can be as simple as a hand drawing or as complicated as a computer-aided design (CAD). The facility diagram should supplement the facility description section of the SPCC Plan, which may include things like facility location, type, size, and proximity to navigable waters.

The facility diagram should provide enough detail and information on it so that your facility may use it for prevention activities, inspections, and response measures.

Required Elements of a Facility Diagram

There are 4 major requirements that EPA will be looking for in a facility map:

  • The location and contents of oil containers greater than 55 gallons (gal)
  • Completely buried tanks that are otherwise exempted from the SPCC rule
  • Connecting piping
  • Transfer stations

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The facility diagram must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located. The facility diagram must also include the location of all underground storage tanks (USTs) even if they are exempted under 40 CFR 112.1(d)(4). The facility diagram must include all transfer stations and connecting pipes, including intrafacility gathering lines that are otherwise exempted.

Where facility diagrams become complicated because of the presence of multiple fixed oil storage containers or complex piping/transfer areas at a facility, an owner or operator may include that information separately in the plan in an accompanying table or key.

For any mobile or portable containers located in a certain area of the facility, an owner or operator can mark the area on the diagram, as well as indicate the potential range in number of containers and the anticipated contents and capacities of the mobile or portable containers.

Recommended Elements

In addition to the required elements, EPA recommends indicating the following on your facility diagram:

  • Secondary containment
  • Storm drain inlets and surface waters
  • Direction of flow in the event of a discharge
  • Legend (with a scale and symbols)
  • Location of response kits and firefighting equipment
  • Location of valves or drainage system controls
  • Compass direction
  • Topographical information and area maps

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It is in a facility’s best interest to include these recommended elements in your facility diagram. If this is what EPA is looking for in your Plan, it would be wise for you to make it easy for them to find it. Remember, a quick EPA inspection of your SPCC Plan is the best kind of inspection!

See tomorrow’s Advisor for some examples of facility diagrams that will help you draw your own.

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