SPCC Applicability and Planning for Odorization Sites
- May 5, 2024
- 2 min read
Updated: Aug 12
In the gas distribution industry, where safety and environmental responsibility are paramount, implementing a Spill Prevention, Control, and Countermeasure (SPCC) plan is a crucial step. This blog post will delve into the importance of SPCC plans, the factors involved in risk analysis and assessment, and the key components to include in a comprehensive spill control plan for odorization sites.
Importance of an SPCC Plan: Spill planning can help a facility organize prevention, response, and documentation. An SPCC Plan is required only when the facility and stored materials meet the applicability criteria in 40 CFR Part 112; odorization activity alone does not establish applicability.
Factors for Risk Analysis and Assessment:
Location of Odorization Site: Proximity to schools, hospitals, residential areas, and businesses.
Other Risks: Consideration of traffic and moving vehicles in the vicinity.
Maximum Odorant Volume: Assessment of the maximum odorant volume stored at the site.
Secondary Containment Type: Evaluation of the type of secondary containment (concrete, steel, cinder blocks, earth berm, or no containment).
Odorant Equipment Position: Whether the odorant equipment is positioned outside or inside.
Fittings Type: Comparison of welded vs. threaded fittings.
Underground Locations and Installations: Consideration of underground installations such as electrical systems and piping.
Prevailing Wind Patterns: Evaluation of wind patterns to assess the potential spread of spills.
Soil Type: Examination of soil type to understand its impact on spill absorption and containment.
Underground Water Table: Understanding the depth and fluctuation of the underground water table.
Guidelines and Components for SPCC Plans:
Follow Regulatory Guidelines: Determine whether 40 CFR Part 112 applies to the facility's oil storage and discharge potential. Do not apply SPCC requirements to an odorization site without a documented applicability review.
Topographical Map: Include a topographical map of the surrounding area, identifying low points where spilled liquids may collect.
Protection of Streams: Implement approved flood control methods like berms, dikes, and secondary containments for odorization equipment to protect nearby streams.
Key Contact Personnel: Provide a list of key contact personnel with phone numbers, including first responders, gas control/gas dispatch center, fire marshal, police, hazmat team, and hospitals for support and equipment.
Where SPCC applies, the plan should address the covered oil storage, discharge pathways, containment or countermeasures, inspections, records, and response responsibilities required for that facility. Where it does not apply, a site may still need product-specific spill planning under other procedures or requirements. BPS provides operational support and documentation, not legal advice.
