Quick Tips on an SPCC Plan

What is a Spill Prevention, Control and Countermeasures (SPCC) Plan?

The purpose of the Spill Prevention, Control, and Countermeasure (SPCC) rule is to help facilities prevent a discharge of oil into navigable waters or adjoining shorelines. This rule is part of the U.S. Environmental Protection Agency’s oil spill prevention program and was published under the authority of Section 311(j)(1)(C) of the Federal Water Pollution Control Act (Clean Water Act) in 1974. The rule may be found at Title 40, Code of Federal Regulations, Part 112.

Do I Need One?

A facility is covered by the SPCC rule if it has an aggregate aboveground oil storage capacity greater than 1,320 U.S. gallons or a completely buried storage capacity greater than 42,000 U.S. gallons and there is a reasonable expectation of an oil discharge into or upon navigable waters of the U.S. or adjoining shorelines.

A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. Operations that are intended to move oil from one location to another, i.e. transportation-related, are not included. Here are some examples of covered facilities and operations:

  • Industrial, commercial, agricultural, or public facilities using or storing oil
  • Loading racks, transfer hoses, loading arms, and other equipment
  • Certain waste treatment facilities
  • Vehicles (e.g. tank trucks) and railroad cars used to transport oil exclusively within the confines of a facility

What Types of Oil Are Covered?

Oil of any type and in any form is covered, including: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils; and other oils and greases, including synthetic oils and mineral oils.

Calculating Oil Storage On-Site Can Be Tricky.  I Don’t Have 1320 Gallons, Do I?

Use the shell capacity of the container (maximum volume) and not the actual amount of product stored in the container (operational volume) to determine whether the SPCC rule applies to you. Count only containers with storage capacity equal to or greater than 55 U.S. gallons. And, don’t forget to include oil-filled equipment like hydraulic systems, lubricating systems (e.g., those for pumps, compressors and other rotating equipment, including pumpjack lubrication systems), gear boxes, machining coolant systems, heat transfer systems, and transformers.

But, How Do I Determine If My Oil Could Reasonably Discharge Into Navigable Waters?

You can determine this by considering the geography and location of your facility relative to nearby navigable waters (such as streams, creeks and other waterways). Additionally, you should determine if ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby streams.

What Do Covered Facilities Have To Do?

The owner or operator of the facility must develop and implement an SPCC Plan that describes oil handling operations, spill prevention practices, discharge or drainage controls, and the personnel, equipment and resources at the facility that are used to prevent oil spills from reaching navigable waters or adjoining shorelines.

Is It True That The SPCC Plan Must Also Be Certified?  If So, By Whom?

Preparation of the SPCC Plan is the responsibility of the facility owner or operator, who may also be eligible to self-certify the SPCC Plan if the facility meets the following eligibility criteria for a qualified facility:

  1. Total aboveground oil storage capacity of 10,000 U.S. gallons or less, and
  2. In the 3 years prior to the date the SPCC Plan is certified, the facility has had no single discharge of oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, or no two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 U.S. gallons within any 12-month period.

If the facility does not meet the above criteria, the SPCC Plan must be certified by a licensed Professional Engineer (PE). By certifying the SPCC Plan, the PE confirms that:

  1. She is familiar with the requirements of the rule;
  2. She or an agent has visited and examined the facility;
  3. The SPCC Plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards, and with the requirements of the rule;
  4. Procedures for required inspections and testing have been established; and
  5. The SPCC Plan is adequate for the facility.

Wow!  This Still Sounds Complex and I May Need PE Certification – What To Do?

Compliance Technologies Inc. has evaluated numerous sites to assist in determining if an SPCC Plan is required and has prepared SPCC Plans for clients in a multitude of industries.  This assures that they have a compliant, properly certified SPCC Plan in-place along with a clear understanding of the spill prevention procedures and responsibilities the company will follow.

Published by Glenn Miller

Senior Compliance Manager Mr. Miller provides a broad range of consulting services to CTI’s clients based on over 30 years of experience in the chemical industry. Along with helping to coordinate CTI’s diverse consulting projects and assisting in CTI’s marketing efforts, he specializes in HazCom programs, dangerous goods handling and labeling (GHS, HMIS and NFPA), transportation compliance (DOT/IATA and IMDG), site audits, global regulatory compliance (REACH, TSCA), Process Safety Management, and training. You may direct questions to our Senior Compliance Manager, Glenn Miller, at 216.341.1800, ext. 14

Leave a comment

Your email address will not be published. Required fields are marked *

Notice Image

Compliance Technologies has joined the August Mack Family. We will redirect this website to the new URL in 10 seconds.