Working at Pipeline Sites with SPCC Regulations

By Erica Sykut, PE, LEED AP BD+C

Pipeline site related projects often pose unique environment permitting issues.  Aside from the typical land disturbance, endangered species, archeological and discharge permits that impact most construction projects, pipeline sites may be subject to Spill Prevention Control and Countermeasure (SPCC) regulations.  These regulations can be tricky to navigate through, especially since the SPCC regulations have only been fully in effect since 2010. 

Any site that has above ground oil storage capacity greater than 1,320 gallons or has had an oil spill in the past three years should have a written Spill Prevention, Control and Countermeasure (SPCC) Plan.  This plan outlines how the facility will operate to prevent oil spills, the measures that are in place to control a spill and the steps that will be taken to clean up a spill.  While an SPCC plan deals directly with oil containers on a site, it also has an impact on the overall site’s layout and should be taken into consideration anytime work is proposed at a regulated site. 

Impacts to a site’s SPCC can be particularly tricky for projects that do not impact oil storage.   Any project that involves below grade work of any kind could impact the site’s plan for managing spills.  Secondary containment measures are the most common site feature to impact SPCCs.  All diked areas within a facility around oil storage containers (including large electrical transformers) should be designed to contain a specific volume.  It is important that any berms or dikes disturbed by a project be fully restored to their original condition as soon as possible within a project’s timeline.  Collection of additional topographic survey data may be prudent to ensure the site is properly restored, especially if a section of a dike wall had to be disturbed for the installation of improvements, or if something is constructed within a diked area.  Contractors and facility operators should also be cautioned when ‘dressing up’ diked areas with gravel or spreading excess fill to avoid transporting soil off site.  This additional material can cause secondary containment to become undersized.

Also as part of the SPCC, site drainage is considered.  In the event of a spill, oil will pool anywhere stormwater does.  If a project involves changing the site’s drainage patterns, the SPCC may need to be revised/updated.  Even if no alterations are planned, it is important that the contractor understand the importance of returning sites to their original grade/condition.   Often contractors bring in extra gravel or spread excess excavated material on site and ‘make it look pretty’ without any consideration to the site’s drainage patterns.  After years of various projects/improves, it is not uncommon for sites to end up with significant extra fill material in some areas and drainage plans that no longer properly function as a result. 

Working at pipeline sites often involves many special considerations.   Because of the nature of work and potential hazards found at these sites, extra consideration to project details is not only warranted but essential to keeping a client in compliance with regulatory agencies.  For further information on SPCC regulations visit: http://www.epa.gov/oem/content/spcc/index.htm or 40 CFR 112 for full SPCC plan guidance.