Environmental, Health & Safety (EH&S) Consulting Case Study

August Mack was retained by a client to complete a Spill Prevention Control and Countermeasures (SPCC) plan for the Ohio plant. The purpose of this project was to ensure the facility’s compliance with the SPCC requirements codified in Title 40 of the Code of Federal Regulations Part 112 (40 CFR 112). The scope of work for this project included compiling pertinent operational information for the site, conducting a site inspection/assessment of the facility and preparing the SPCC plan for the site.

The facility has sufficient above ground petroleum storage capacity to trigger SPCC requirements (total above ground storage greater than 1,320 gallons). August Mack requested information such as facility layout diagrams, secondary containment descriptions and current spill response procedures. The facility was visually inspected by August Mack staff to confirm tank capacities, secondary containment capacities and tank locations. A site plan was developed denoting tanks, piping, secondary containment and spill kits. 

A SPCC plan was prepared for the site that specified the current conditions at the facility, and presented the activities and implementation schedules for minimizing the potential for spills of petroleum products. More specifically, the plan identified key personnel responsible for implementing the SPCC plan, discussed previous spills, predicted the direction, rate of flow and total quantity of petroleum discharged for a possible spill, reviewed containment structures and storage vessels, identified spill response/notification procedures and provided a Professional Engineer’s review and certification. The SPCC plan was completed incorporating the latest adopted 40 CFR 112 rules.

If you are interested in learning more about August Mack's Environmental, Health & Safety Consulting experience, please contact Tom Anderson at 317.916.3105 or via e-mail at tanderson@augustmack.com.