Spill Prevention and Control and Countermeasures Plan, SPCC

EPA in 1973, issued the Spill Prevention and Control, and Countermeasure (SPCC) regulations that require specific businesses and facilities that store over 1320 gallons of oil to prevent, prepare for, and respond to oil discharges that may negatively impact and reach navigable waters of the United States and their adjoining shorelines.  The purpose of creating your site specific SPCC Plan for your industrial oil storage facility or commercial building complex with generators and transformers was designed to prevent oil releases.  In particular the SPCC Plan (under the Oil Pollution Prevention Act) required by EPA must include how to develop, maintain and implement an oil spill prevention program that designates at your facility how to respond to an emergency release of oil to prevent the oil from impacting the environment and waters of the US. EPA’s regulations at 40 CFR 112, requires covered facilities to reduce the risk of oil spills and develop steps to address any releases. This ensures that facilities which store oil quantities above 1,320 gallons have in place containment and other countermeasures to prevent oil spills from reaching navigable waters or adjoining shorelines. At Best in the West Safety we have helped many facilities with oil storage create an environmentally compliant SPCC plan to help them navigate the EPAs Clean Water Act requirements to protect the environment.  Our Certified Environmental Professionals and Professional Engineer are ready to work with your business to create a customized SPCC Plan and Spill Response Clean Up measures that meets the environmental regulation requirements and provides you with the peace of mind that your facility is ready for an unplanned and unprecedented release of oils.

 We have written new facility and updated SPCC Plans all the while we guided businesses to the correct active and passive control measures to implement and install to prevent oil releases from traveling offsite and planned clean up response measures and created spill control and response kits for active clean up response. So if your facility has more than 1,320 gallons of oil you are responsible for having an SPCC Plan and preparing for spill clean up responses and developing onsite control measures to stop the flow of oil offsite.   We can provide onsite training to help your employees respond to oil releases and write your EPA SPCC Plan.  Select the contact us button to get started.

Sounds confusing?  Unsure where to start.  Let Best in the West Safety write your SPCC Plan and create the facility training programs and inspection checklists so that your business will be in compliance with the EPA regulations and more importantly you have implemented protective measures to prevent an oil release and your employees are trained and prepared to respond to an oil spill.  Contact us today  by clicking the button above to get the answers and help you need.

• You are a facility that stores greater than 1,320 gallons of Oil
• Your storage containers that count towards the 1,320 gallons starts at 55 gallon drums and larger.
• Your facility has a “reasonable expectation of an oil discharge” to water (may be through storm drains and other offsite travel pathways.
• Facilities that store over 10,000 gallons of oil must have a professional engineer certify their SPCC Plan. Less than that amount a facility may choose to self-certify.

• with smaller oil storage capacity,
• and that have not had oil spills.

The owner or operator of a “qualified facility” can prepare and self-certify an SPCC Plan rather than have a Professional Engineer (PE) review and certify the Plan.

There are two types of qualified facilities, Tier I and II. To determine if you have a qualified facility, you need to:

• know the total capacity of aboveground oil storage containers at the facility, and
• information on oil spills from the facility for the past three years.

SPCC Applicability

A facility will only be subject to the Spill Prevention, Control and Counter Measure rule must first and foremost meet the following three criteria:

1. The facility operations must be non-transportation-related,
2. The facility must have an aggregate aboveground storage capacity of greater than 1,320 gallons or a completely buried storage capacity of greater than 42,000 gallons, and
3. The facility owners/operators must have a reasonable expectation of a discharge into or upon navigable waters of the United States or adjoining shorelines.

Helpful Guidance and Regulations

EPA  SPCC Plan Guidance for Qualified Facilities Applicability

EPA SPCC Rule and Recent Amendments Presentation

EPA Part 112 Oil Pollution Prevention

Questions and Answers

1. I own a gasoline fuel station do I need an SPCC Plan?

Commercial resale fueling stations do not require a SPCC Plan.

2. What types of oil storage containers count towards my total capacity to determine if I am required to have a SPCC Plan?

A facility that stores oil in any type of container, both above and below ground (including piping associated with the tanks) and those containers that are larger than 55 gallons counts towards the total capacity of 1,320 gallons.

3. What are the exclusions for the holding capacity of oil to count towards the total oil capacity for our facility that do not count towards our totals?

Any facility which, although otherwise subject to the jurisdiction of EPA, meets both of the following requirements:

(i) The completely buried storage capacity of the facility is 42,000 U.S. gallons or less of oil. For purposes of this exemption, the completely buried storage capacity of a facility excludes the capacity of a completely buried tank, as defined in § 112.2, and connected underground piping, underground ancillary equipment, and containment systems, that is currently subject to all of the technical requirements of part 280 of this chapter or all of the technical requirements of a State program approved under part 281 of this chapter, or the capacity of any underground oil storage tanks deferred under 40 CFR part 280 that supply emergency diesel generators at a nuclear power generation facility licensed by the Nuclear Regulatory Commission and subject to any Nuclear Regulatory Commission provision regarding design and quality criteria, including, but not limited to, 10 CFR part 50. The completely buried storage capacity of a facility also excludes the capacity of a container that is “permanently closed,” as defined in § 112.2 and the capacity of intra-facility gathering lines subject to the regulatory requirements of 49 CFR part 192 or 195.

(ii) The aggregate aboveground storage capacity of the facility is 1,320 U.S. gallons or less of oil. For the purposes of this exemption, only containers with a capacity of 55 U.S. gallons or greater are counted. The aggregate aboveground storage capacity of a facility excludes:

(A) The capacity of a container that is “permanently closed” as defined in § 112.2;

(B) The capacity of a “motive power container” as defined in § 112.2;

(C) The capacity of hot-mix asphalt or any hot-mix asphalt container;

(D) The capacity of a container for heating oil used solely at a single-family residence;

(E) The capacity of pesticide application equipment and related mix containers.

(F) The capacity of any milk and milk product container and associated piping and appurtenances.

For a total list of exclusions refer to the CFR:  https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-112

4. What types of oils apply to the SPCC Plan?

The SPCC Plan applies to Oil of any kind in any form and various types of oil, including but not limited to petroleum oils.  Petroleum oils—include crude and refined petroleum products, asphalt, gasoline, fuel oils, naphtha, sludge, oil refuse, and oils mixed with waste other than dredged spoils.  Included in the definition are animal fats and vegetable oils, alcohols, biodiesel,  synthetic oils natural gas and oil and water mixtures.  In 2011, EPA exempted milk and milk product containers and piping from the rule.

5. Does the SPCC Plan only cover petroleum based oil products?

No, it includes many other types of oils such as, alcohol, vegetable oils, biodiesel products, animal fats, oil sludge and oil mixed with wastes.

6. I have multiple electrical transformers and generators at my facility with fuel oil or oils that exceed the total quantity of 1,320 gallons for all of the units. Do I need an SPCC Plan?

It depends, first and foremost, is there a potential for the oil to be released to a water of the US.  Secondly, do you have a total capacity of oil (that meets the EPA definition) exceeding 1,320 gallons then Yes you are required to have a SPCC Plan to prevent oil releases and prepare to emergency releases and clean up.

7. I have multiple oil containers and drums that together exceed the capacity of 1,320 gallons. Do my 5 gallon and 15 gallon pails apply towards my total?

No, only 55 gallon and larger containers, above and below ground storage tanks and their piping count towards the total capacity required under EPA’s SPCC Plan.

8. AT my facility I have reached the capacity of 1,320 gallons to have a SPCC Plan. I also have tank trucks and mobile refuelers.  Are these vehicles exempt from the SPCC requirements and totals?

EPA exempted transportation related tank trucks hauling fuel and oils.  However, not all tank trucks or refueling tanker trucks are exempt from SPCC. Only those activities subject to DOT jurisdiction fall outside the scope of SPCC regulation. For example, EPA regulates tank trucks (or mobile refuelers) under the SPCC rule, if they operate exclusively within the confines of a non-transportation-related facility (i.e. fuel trucks at airports or at large mining operations).

EPA also regulates the activity of loading or unloading oil in bulk into storage containers (such as those on tank trucks or railroad cars), as well as all equipment involved in this activity (e.g., a hose or loading arm attached to a storage tank system).