“Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility.”
Wait, what is that supposed to mean? What written procedures should I incorporate into my inspections? What am I supposed to be looking for to satisfy this requirement?
The truth is, the SPCC rule is very open-ended, performance-based and, in a way, subjective. Thus, questions like “what should my SPCC inspection consist of?” and “how often should I inspect?” come up very often. As long as you use “good engineering practices” and “applicable industry standards”, it’s easy peasy! Let’s dive in and see what some of our SPCC Inspection best practices look like.
#1 Implement oil-filled equipment integrity testing.
The SPCC rule covers oil storage containers that have a storage capacity of 55 gallons or more. With that being said, you may have oil storage containers that are solely used for oil storage or you may have oil-filled equipment that contains an oil reservoir of 55 gallons or more, on your site. Both of these types of containers may apply under the SPCC rule. Although the SPCC rule does not require equipment that contains an oil reservoir to be inspected, our best practice is to implement oil-filled equipment integrity testing anyway. There are usually manufacturer recommended inspection/testing schedules, but if you do not find any, it best to inspect for the following:
- Functionality of the equipment
#2 Inspect on a monthly basis.
We recommend that inspections are performed on a monthly basis for containers, equipment and associated pipes/valves to ensure compliance with the SPCC rule and to ensure functionality of your oil storage. The items inspected above for oil-filled equipment should also be applied for inspections of associated pipes/valves and oil storage containers. The Mapistry SPCC module has incorporated the essentials to maintain compliance with the SPCC rule by creating inspection forms that will allow you to check on the integrity of your oil storage containers, oil-filled equipment and all associated piping and valves. It will also remind you when inspections are due and allow you to keep all of your records in one easy to access and centrally located software platform.
#3 Look at your surroundings.
It is super important to not only look at your storage containers/pipes, but to also look around at the general area where your oil storage is located. You should be looking at:
Any secondary containment that you have for your oil storage
Your secondary containment should be free of oil, water, debris, etc. and should be functional. It should not have any cracks or leaks and it should have sufficient capacity to contain the entire capacity of the storage tank plus precipitation.
What’s wrong with this picture?…………………..
……………You guessed it. Too small! The industry standard is to have secondary containment with 110% of the volume capacity of the oil storage container. All of the oil in this container cannot possibly fit in the secondary containment WITH precipitation. These kind of observations can make the difference between being in compliance and receiving a violation.
Surrounding soil/flooring can always help in signaling some kind of leak. There are many oil storage containers, especially oil-filled equipment, that are much harder to get to or harder to inspect in general, and noticing oil on the floor can help you determine if something is wrong and needs to be fixed.
General containment should be nearby: functional and complete (i.e. spill kits)
In areas where oil storage or oil transfer (fueling stations) is present, it is always important to have spill kits or other types of general containment nearby. If you have an oil spill and you have your 30-gallon spill kit nearby, it is really easy to contain the spill. Here are some steps for cleaning up a spill with your spill kit:
- Put your shades on! (safety glasses)
- Put on nitrile gloves
- Place your absorbent socks/snakes around any nearby drains and around the spill itself
- Use absorbent pads and pillows to absorb the spill. Pads and pillows should be placed directly above the spill. Please note that pillows absorb more liquid than pads do.
- Once the spill has been cleaned up, place your used absorbent materials into your bags with ties for disposal. It is usual practice to keep all oily materials in a tightly closed drum and have a contractor remove them from your facility.
#4 Tightly close containers and valves.
Ensure that all oil storage containers and associated valves are completely closed when not in use and after each authorized use. Drums, large containers, etc. need to be tightly closed to avoid leaks or spills and if, for any reason, the valves are planned to be opened, you must take the proper steps to ensure that the oil released is contained.
#5 Labels are your friend.
Adding adequate labeling to all of your oil storage containers and equipment can help you not only stay in compliance, but also helps with keeping inventory of what you have at the facility and having people unfamiliar with your site (emergency responders), quickly locate your containers. Suggestions on what to include on your label are:
- Capacity of the tank
- Type of oil stored inside of it
- Tank Name or ID
- All Applicable Placards
Please keep in mind that your applicable placards may require you to put in other information such as accumulation date, 90-day hazardous waste storage date, etc. Thus, making sure that you are filling in the correct spaces on your label with the correct information is crucial!
#6 Ask the question. Are we using this?
Check every once in a while if you are ACTUALLY using the capacity of your container. If you are using a 55 gallon container, but using only 20 gallons of it all the time, you can get a smaller container and have one less container you have to inspect! Just be careful when transferring the oil, you wouldn’t want to SPILL it! Hehe.