Question: I’m in the process of writing a Spill Prevention Control and Countermeasures (SPCC) plan for my facility, and I’m a little overwhelmed. My main concern is a 1,400 gallon oil tank that could leak into a drain that discharges to a nearby creek. The drain can’t be permanently closed because condensate from the HVAC unit drains to it. What can you recommend that I do to prevent a discharge to the drain if the tank fails overnight while no one was there?
Answer: There are a number of realistic options that should be fairly easy to implement and won’t break the bank. Secondary containment systems and drain covers will protect your drain from an oil spill while the facility is unmanned.
Secondary containment systems are fairly easy to install or retrofit into facility designs and use walls, dikes or other means to stop a spill from traveling beyond the barrier that is created by the containment structure. Some even provide containment without sacrificing accessibility. With a containment berm, for example, you’ll still be able to access the area with carts and forklifts. And, since these berms aren’t permanent, you can also move them if the facility design changes or the tank needs to be moved.
Drain covers seal off a drain entirely, blocking anything from entering. They’ll prevent spilled oil from entering the drain while no one is looking. The tradeoff is that the crew arriving on Monday morning is going to need a large vacuum and a big spill kit if there is a spill.
You might also consider plumbing a line from the compressor to the drain and sealing the drain, but remember that compressor condensate often contains trace amounts of oil, so you may want to consider filtering that before discharge. You’d also need to determine if the tubes or piping present a trip hazard for workers. But, if you do plumb the condensate to the drain, the rest of the drain could then be sealed to prevent the oil in the tank from entering the drain if the tank fails.
Some other options include diverting the drain to a retention pond or using pipe plugs at the outflow to prevent a spill from entering the stream. Each option has its pros and cons, and there are likely a dozen others that I haven’t mentioned.
The good news is that even though Environmental Protection Agency mandates that oil can’t leave your facility, they don’t mandate how it must be done. This gives your company the liberty of choosing whatever method is the most effective for your specific situation and needs.
More good news is that inspectors and auditors look for realistic procedures, processes and equipment in SPCC plans, so you’re not obligated to choose expensive options when low-cost ones will be just as effective. Consider this example from an SPCC plan:
“To be prepared for spills from our outdoor oil tanks, ABC Facility stores 3,000 feet of absorbent boom in a shed near the boat dock.”
That looks fantastic on paper, but here’s where that plan fails:
- ABC Facility doesn’t have a boat or any other equipment to deploy the booms
- ABC Facility only employs 20 people over three shifts. First shift has 15 people, including one security officer and 13 traveling salesmen. That realistically leaves 2 people available for a “response”
- Facility personnel only have awareness-level training
- ABC Facility has an outside spill response contractor that is located 40 miles from the facility. By the time the contactor arrives, anything that has spilled will be miles downstream
Now, don’t get me wrong — 3,000 feet of absorbent boom is a great thing. I can think of several facilities that would love to have that kind of budget, as well as space to store it all. But, unless you have the equipment and manpower to go with it, the money spent on this particular solution would be wasted.
Run the idea by the shop foreman or a couple of your onsite engineers. They should have a firm grasp on what will or won’t work – and their ingenuity will lead to the solution that makes the most sense for your workspace.