Developing an SPCC Plan? Confused about SPCC compliance? We’ve compiled the answers to the most common questions below.
- What does SPCC stand for?
- What regulation does the SPCC rule fall under?
- Do I fall under the SPCC rule?
- What do I need to do if I fall under the SPCC rule?
- What are the requirements for the SPCC plan?
- How often do I update my SPCC plan?
- What types of oil are covered under SPCC?
- Is milk covered under SPCC?
- Does a licensed Professional Engineer (P.E.) need to certify my SPCC plan?
- What are the criteria to self-certify my SPCC plan?
- What is the difference between a bulk storage container and oil-filled equipment?
- Do I need to do any inspections for SPCC?
- What do I need to inspect?
- When do I perform inspections?
- When do I use general secondary containment?
- What are some examples of general secondary containment?
- When do I use sized secondary containment?
- How do I "size" my secondary containment?
- What do I do if I have stormwater in my secondary containment?
- If I have a spill, who do I call?
- Contact Us
Spill Prevention, Control, and Countermeasure
The SPCC requirement falls under the Oil Pollution Prevention regulation (40 CFR Part 112). The Oil Pollution Prevention regulation also houses the Facility Response Plan requirement. For more information on whether your site requires a Facility Response Plan, click here.
Facilities that store, process, refine, use or consume oil or oil products & do not participate in the transportation fall under the SPCC rule if:
- There is a “reasonable expectation of an oil discharge” to navigable waters
AND if you satisfy one of the following:
- You have greater than 1,320 gallons of total aboveground oil capacity
- You have greater than 42,000 gallons of total underground oil capacity
You must prepare and implement an SPCC plan.
- Describe the physical layout of the facility and include a facility diagram
- Container/Associated piping
- Transfer stations (i.e., fueling islands)
- Must mark the location and contents of each
- Address/Describe the following:
- Oil type & storage capacity of all applicable containers
- Discharge prevention measures
- Discharge or drainage controls
- Countermeasures for discharge discovery, response, and cleanup
- Procedures to follow in case of a discharge
You must update your SPCC plan every five years or when changes are made to the facility.
All types of oil and oil products are covered under SPCC. These range from motor oil all the way to vegetable oil. Some more examples include:
- Olive Oil
- Avocado Oil
- Fuel Oil
- Used Oil
- Animal Fats
No, milk is not covered under SPCC. In 2011, an amendment to the SPCC regulation exempted milk and milk-based products. Click here for more information.
Yes, you do need a licensed P.E. to certify your SPCC, unless you meet the criteria to self-certify.
If you meet the following criteria, the facility owner or operator may self-certify their SPCC plan:
- Total aboveground oil storage capacity of 10,000 gallons or less, and
- 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 gallons, or no two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 gallons within any 12-month period.
If you do not meet the criteria to self-certify specified above, the SPCC plan must be certified by a licensed Professional Engineer (P.E.).
For more information on self-certifying, click here.
Bulk storage containers are containers that are solely used to store oil (i.e., AST's, drums, totes), whereas, oil-filled equipment has an oil storage container(s) to support the function of the device (i.e., Transformers. hydraulic systems, circuit breakers).
Yes, you do have to do inspections for SPCC.
You will need to inspect SPCC applicable bulk storage containers associated piping/valves for damage, corrosion, leaks, and functionality, as well as, secondary containment for completion and functionality. Below is a screenshot of the questions in the Mapistry inspection sheet.
Mapistry also recommends that the following items also be inspected as best practices:
- Oil-filled equipment for leaks, damage, corrosion and functionality
- Proper sizing of secondary containment and secondary containment is free of debris
- Valves and storage containers themselves are closed completely
- Surrounding soil/flooring for any indication of oil
- Any spill kits on-site are complete with all required elements
The frequency at which you perform your SPCC inspections will be stated in your SPCC plan. It is best to follow the manufacturer's inspection schedule, but if those are not available, the industry standard is to perform inspections monthly.
At a minimum, all areas with the potential for an oil discharge require general secondary containment. These areas may include:
- Bulk storage containers
- Mobile/portable containers
- Mobile Refuelers
- Oil-filled equipment
- Loading/unloading areas
For more examples, click here and reference section 4.2.
- Retention ponds
- Sorbent Materials
For more examples, click here and reference 40 CFR Part 112.7 (c).
Sized secondary containment is required in the following areas:
- Loading/unloading racks
- Bulk storage containers
- Production facility bulk storage containers
Sized secondary containment must be designed to contain the capacity of the bulk storage container plus appropriate freeboard for precipitation. The industry standard has been to have the capacity of 110% of your total bulk storage container capacity.
If you have stormwater in your secondary containment, you may be able to dispose of it as stormwater. First, you must complete a bermed release form. A bermed release form will ask whether you can spot the presence of oil in the water. If there is no sign of oil, you may release it as stormwater, but if there is a sign of oil, you will need to dispose of the water as oil waste and investigate the origin of the oil. Below is an example of information required in the Mapistry bermed release form.
If a reportable quantity was released off-site, call the National Response Center at (800) 424-8802.
If the spill is 1,000 gallons or more or if there are two oil spills of 42 gallons or more in a 12-month period, call the US EPA Spill Hotline at (800) 300-2193.
You may need to contact local and/or state-specific agencies regarding oil spills, as well. Please refer to your SPCC plan for that contact information and the circumstances in which you will need to contact them.
Have other questions regarding SPCC that could not be answered by this article? Contact us at (800) 553-7420 or firstname.lastname@example.org.