Creating an SPCC Plan
Background
In 1973, the EPA issued the first set of regulations dedicated to preventing, preparing for, and responding to the discharge of oil. These regulations (40 CFR 112) require some facilities to create, implement, and maintain a Spill Prevention, Control, and Countermeasure (SPCC) Plan. It can be difficult to determine what rules in Part 112 apply to your facility, so the following steps were created to simplify that process.
Step 1: Do the rules of 40 CFR 112 apply to your facility?
- Is the total aboveground oil storage capacity greater than 1,320 gallons of oil? Is the total completely underground oil storage capacity greater than 42,000 gallons of oil?
- Note: Only oils that are in containers that have a capacity of 55 gallons or more are considered. This may include pipes, equipment, transformers, etc. Oils stored in smaller quantities are not considered as a part of the inventory for the SPCC plan or counted toward the 1,320 gallons threshold.
- Is the facility considered non-transportation related?
- Is the facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil?
- Could the facility reasonably be expected to discharge oil in quantities that may be harmful into navigable waters or adjoining shorelines?
If the answer to any of the above questions is a yes, you will need an SPCC plan.
Step 2: Determine the type of SPCC plan needed.
Determine the maximum oil storage capacity of the facility and the largest individual storage container on site, and then use the table below to determine what type of SPCC plan the facility is subject to along with the applicable regulations and certification requirements.
| Type | Maximum Oil Storage Capacity | Largest Aboveground Individual Container | Applicable Regulations | Certification |
| Tier I | < 10,000 gallons | < 5,000 gallons | Template in Appendix G of 40 CFR 112 | Self-certified |
| Tier II | < 10,000 gallons | ≥ 5,000 gallons | 40 CFR 112.7 and subparts B or C | Self-certified |
| All Other Facilities | ≥ 10,000 gallons | Any Size | 40 CFR 112.7 and subparts B or C | Certified by a Professional Engineer |
*Note – To be considered a Tier I or Tier II facility, there must be no single discharge to navigable waters or adjoining shorelines that is greater than 1000 gallons nor two discharges of 42 gallons within a 12-month period.
Step 3: Write your SPCC Plan
Write your plan according to the applicable regulations above and certify as the rule states. To start writing your SPCC plan, collect your oil inventory and review the facility for spill prevention structures, equipment, or procedures that are already in place. Although self-certification is available for Tier I and Tier II facilities, SEC strongly recommends having a professional engineer review the SPCC plan to validate effective practices are in use and to reduce the need for a full rework of your plan if any process changes occur.
Step 4: Maintaining your SPCC Plan
- The SPCC plan must be maintained at a location in the facility that is normally attended at least 4 hours per day.
- The plan must be reviewed at least every 5 years and updated as appropriate. If updates include technical amendments that affect the potential for a discharge or if the changes affect the facility’s classification such that it can no longer be classified as a Tier I or Tier II facility, it must be certified by a professional engineer.
- Plan amendments must be made whenever changes are made to the facility that materially affect the potential for a discharge.
Need EHS Support, Reach Out
If you have any questions regarding SPCC Plans or need support with an EHS related project, please contact Carter Venable at Carter@StevensEHS.com.
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