Spill Prevention, Control and Countermeasure (SPCC) Training

Introduction to SPCC
Under the Spill Prevention, Control, and Countermeasure (SPCC) Regulation, “oil” is very widely defined and includes, but is not limited to, petroleum, fuel oil, oil refuse and sludge, animal fats, oils or greases, vegetable oils and greases and other oils and greases including synthetic and mineral oils.

A facility is subject to SPCC and required to prepare and implement an SPCC plan if it has an aggregate aboveground capacity greater than 1320 gallons in containers 55-gallons or greater or an underground capacity greater than 42,000 gallons and there is a reasonable expectation of a discharge into a navigable waterway or adjoining shoreline.

Plans must be reviewed and amended every five years or when facility information (personnel, oil sources, etc.) change. Elements of an SPCC plan include:

• Facility description and diagram
• Discharge calculations
• Secondary containment
• Likely spill path
• Site security
• Facility Inspections
• Container requirements
• Transfer procedures and equipment
• Training and recordkeeping requirements
• Management approval and plan certification

Spill Prevention, Control, and Countermeasure (SPCC) Regulation – 40 CFR 112
SPCC means Spill Prevention, Control and Countermeasure.  The SPCC regulation is issued by the United States Environmental Protection Agency in 40 CFR 112.  The SPCC regulation contains requirements for oil spill prevention, preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines.

Originally published in 1973 under the authority of §311 of the Clean Water Act, the Oil Pollution Prevention regulation sets forth requirements for: the prevention of, preparedness for, and response to oil discharges at specific non-transportation-related facilities.

The goal of 40 CFR 112 is to prevent oil from reaching navigable waters and adjoining shorelines, and to contain discharges of oil. The regulation requires these facilities to develop and implement Spill Prevention, Control, and Countermeasure (SPCC) Plans and establishes procedures, methods, and equipment requirements (Subparts A, B, and C).

In 1990, the Oil Pollution Act amended the Clean Water Act to require some oil storage facilities to prepare Facility Response Plans. On July 1, 1994, EPA finalized the revisions that direct facility owners or operators to prepare and submit plans for responding to a worst-case discharge of oil (Subpart D).

When a professional engineer certifies the spill prevention, control and countermeasures plan, it attests that the engineer is familiar with the requirements of 40 CFR 112, the engineer (or agent) has examined the facility and the plan is acceptable for that facility, the SPCC plan was prepared using good engineering practice (accounting for applicable industry standards) and in accordance with the requirements of 40 CFR 112, and that procedures for inspections and testing have been established.

What is Considered Oil Under SPCC?
It is also important to understand that oil, as it’s defined in the regulation, comes in many different forms including:

• Petroleum Based Oils – Gasoline, diesel fuel, motor, heating, aviation fuels, and hydraulic fluid;
• Non Petroleum Oils – Animal-based, vegetable, biofuels, seed, nut, fruit and kernel; and
• Oil Containing Products – Oil-based paints, thinners and inks, petroleum-based parts, and roofing tar

Spill Prevention, Control and Countermeasure (SPCC) Rule

• Regulatory Overview
• SPCC Applicability
• Qualified Facility Determination
• SPCC for Agriculture
• SPCC for the Upstream Sector
• Frequent Questions

SPCC Guidance and References

• SPCC Guidance for Regional Inspectors
• SPCC Reference Materials
• Secondary Containment Calculation Worksheets
• Tank Inspections

What facilities are subject to the SPCC regulation?
A facility is subject to the SPCC regulation if it meets the following three criteria:

1. The facility must be non-transportation related;
2. The facility must have a combined above-ground storage capacity greater than 1320 gallons or a buried storage capacity greater than 42,000 gallons; and
3. There must be a reasonable potential for a discharge into or upon U.S. navigable waters or adjoining shorelines.

The SPCC rule applies to owners or operators of non-transportation related facilities who drill, produce, store, process, refine, transfer, distribute, use or consume oil or oil products that meet at least one of the capacity thresholds and have the potential to discharge oil to U.S. navigable waters or adjoining shorelines.

SPCC Plan Contents and Certification
A spill prevention, control and countermeasures plan must discuss how the facility meets the requirements for oil spill prevention and containment. The plan must detail in writing the equipment, workforce and steps required to prevent, control and mitigate an oil discharge. The general requirements for SPCC plans are located in 40 CFR 112.7.

Preparation of the SPCC plan is the responsibility of the facility owner or operator, or it can be prepared by an engineer or consultant, but it must be certified by a registered Professional Engineer. By certifying the SPCC plan, the Professional Engineer attests that:

• He/she is familiar with the requirements of 40 CFR Part 112;
• The engineer or their agent has visited and examined the facility;
• The plan has been prepared in accordance with good engineering practices;
• Procedures for required inspections and testing have been established; and
• The plan is adequate for the facility.

An SPCC Plan is unique to each  facility, describing the particular configuration of the site ‘s Aboveground Storage Tanks (ASTs) and even the site’s  Underground Storage Tanks (USTs) for sites exceeding 42,000 gallon capacity.  However, common to  all SPCC Plans  is a listing of  whether or not a site complies with the set of general requirements under 40 CFR 112 . The EPA periodically performs on-site inspections to assure compliance with the SPCC Plan regulations. Facilities are now required to submit information if in a 12 month period the site has had two or more releases of over 42 gallons or a single release of more than 1,000 gallons. The EPA will levy a fine for each item found to be in non-compliance. There is even a fine for failing to list within your SPCC Plan the areas of non-compliance at the site.

You must keep a copy of your SPCC Plan at your facility, if you operate the Aboveground Storage Tank (AST) facility more than four hours a day. If you operate the Above ground Storage Tank (AST) site less than four hours a day you may keep your SPCC Plan at the nearest field office. The EPA requires that a SPCC Plan be available to the EPA for on-site review and inspection during normal working hours.