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Spill Prevention and Countermeasure Plan for Containment Curbs

November 7, 2012

An estimated 300,000 disabling injuries occur each year in the American work force, resulting in 1,400 worker deaths.  Slips, trips and falls account for 15 to 20 percent of all workers compensation costs.  In facilities where equipment can spill or water, oil, and other liquids collect, containment curb installation is common.  It is important to have a countermeasure plan in place in order to maintain and ensure continued safety around such areas.  Reference the following as you formulate or review a spill prevention, control, and countermeasure plan for containment curbs:

  • Purpose of the plan and intended actions should be outlined:
    • To meet the requirements of the US Environmental Protection Agency (USEPA) contained in Title 40, Code of Federal Regulations, 40 CFR 112.
    • To meet the requirements of any other organizations or agencies of the jurisdiction the facility is within or a member of.
    • A prepared facility response plan for any violations found in inspections or preventative assessments.
    • Designate a record keeping system for reports and inspections to be legible and easily identifiable.
  • Past spill history is recorded as follows:
    • Date;
    • Description of spill;
    • Corrective actions taken;
    • Plan for prevention recurrence;
    • Personnel who reported it;
    • Personnel who reviewed it upon completion.
  • An inspection schedule should be created and observed as follows:
    • Inspections consisting of a complete walk through of the tank area to check for security problems, tank damage or leakage and stained or discolored ground surfaces.
    • All bulk storage tanks are inspected monthly. Generator and fire pump tanks are inspected and tank information recorded as they are exercised weekly.
  • Spill information must be reported to USEPA if their thresholds are reached or exceeded, the report shall contain the following:
    • Name of the facility;
    • Name(s) of the owner or operator of the facility;
    • Location of the facility;
    • Cause of the spill(s); Corrective actions and/or countermeasures taken including adequate description of equipment repairs and/or replacements;
    • Information the regional administrator may reasonably require pertinent to the plan or spill event;
    • Date and year of initial facility operation;
    • Maximum storage or handling;
    • Description of the facility, including maps, flow diagrams, and topographical maps;
    • Failure analysis of the system and sub-system in which the failure occurred;
    • A complete copy of the plan with any amendments; and
    • Additional measures taken (preventative) or contemplated to minimize the possibility of recurrence.
  • Personnel should be trained and briefed on the countermeasure plan.
    • Annual spill prevention briefings are provided by the Office of Environmental Health and Safety for operating personnel to ensure adequate understanding of the plan.  These briefings highlight any past spill events or failures and recently developed precautionary measures.
    • Training is held on oil spill prevention, containment, and retrieval methods.  Records of these briefings and spill prevention training are kept on file.
    • Instructions and phone numbers regarding the reporting of a spill and are posted in main areas.
    • Signs are required to be posted at all tanks listing emergency contacts in the event of an oil release.
  • Evaluate if any environment surrounding curbs requires additional slip resistance.
    • If extra slip resistance is deemed necessary, non slip plate can be retrofitted to the curb to maximize the safety in and around the containment curbs.
  • The plan itself should be amended within six months of each of the following occasions:
    • Whenever there is a change in facility design or construction.
    • If the operation or maintenance materially affects the facility’s spill potential.
    • If more effective technology would significantly reduce the likelihood of a spill event and has been proven in the field.
  • Maintenance of the plan should be considered and routinely reviewed:
    • Product, material, and technologies incorporated are all assessed.
    • Thorough review once every five years and amended to include more effective prevention and control technology.

Manley, Agnes. “SPCC Plan/EHS.” Morehead State University, Aug. 2010. Web. 26 Oct. 2012. <www2.moreheadstate.edu/files/…/SPCC%20Plan%209.10.docx>.

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