SPCC Plans & SPCC Plan Types

An EPA SPCC plan is designed to prevent oil spills.

The SPCC Plan gives the EPA assurance the location has a process  in place to prevent spills from the above ground tank.   Typically these plans make sure the site has the proper mechanism & equipment to contain spills.  The SPCC plan also details the countermeasures that are used to prevent oil spills.  In the event a spill occurs, regulators believe that an EPA SPCC plan will prevent an oil spill from impacting streams, creeks, lakes, ponds and other surface water.   SPCC plans are not spill contingency plans which focus solely on the actions taken AFTER a spill has occurred.

An SPCC plan must be prepared in accordance with the oil pollution prevention guidelines in the Federal Code of Regulations 40 CFR, 112.

What kind of SPCC plan do you need?

We’ll try to make this as easy as possible. Follow these steps:

1. Determine whether you need an SPCC plan.  If you’re on this page, we’ll assume you need a plan & must comply with 40 cfr 112.  If you have no idea what this is, see our SPCC requirements page and come back here again.
2. Add up all the above ground oil storage capacity at your location.  When making this calculation, add up all oil containers that hold at least 55 gallons.  You do not have to add any container that holds less than the 55 gallon amount.
3. If the total above ground storage is less than 10,000 gallons, owners can self certify their SPCC plan.   This is good news because the plans have streamlined requirements &  do not require an engineer.  Find out more details at our SPCC self certification page.
4. If the total capacity of all above ground storage added together exceeds 10,000 gallons, you need a full blown SPCC plan.

How hard is it to develop an SPCC Plan?

There are three levels of SPCC requirements for preparation, depending on the sizes of the storage containers located at the facility.

Tier I

Simplest SPCC plan for a small facility that:

• Has 10,000 gallons or less aggregate above ground petroleum storage capacity. Any individual above ground petroleum storage container may be no greater than
• 5,000 gallons.Within any twelve-month period, three years prior to the Plan certification date,
• there has been:
  • No single discharge of petroleum to navigable waters or adjoining shorelines exceeding 1,000 gallons;
    
  • No two discharges of petroleum to navigable waters or adjoining shorelines each exceeding 42 gallons.

Plan Requirements: Owner or operator may complete and self-certify plan template instead of a full Professional Engineer certified Plan. May also prepare and SPCC plan according to Tier II.

Tier II: Modest SPCC plan for a small to mid-sized facility that:

• Has 10,000 gallons or less aggregate above ground petroleum storage capacity.
• Has individual above ground petroleum storage container greater than 5,000 gallons.
• Must meet all other Tier I discharge conditions.

Plan Requirements: Owner or operator may prepare self-certified Plan in accordance with requirements of 40 CFR, §112.7, in lieu of a Professional Engineer certified plan or may also prepare an SPCC plan according to all other facilities’ requirements.

All Other Facilities: Most difficult for a larger facility that:

• Has more than 10,000 gallons aggregate above ground petroleum storage capacity
• Must meet all other Tier I and Tier II discharge conditions.

Plan Requirements: Must prepare a Professional Engineer certified Plan in accordance with all the applicable requirements of §112.7.

A SAMPLE SPCC PLAN can be found at

http://www.epa.gov/emergencies/docs/oil/spcc/guidance/D_BulkStoragePlan.pdf

A full blown SPCC plan is comprehensive.

These SPCC plans must be certified by a professional engineer (PE).  You cannot use a standard template and cannot certify the plan yourself.

In our experience, most larger facilities falling under this classification already have an SPCC plan in place.   Because the EPA issued new SPCC regulations, the SPCC plan probably needs updating.  We’ve reviewed many existing plans and have see deficiencies in areas where regulators are most likely to examine.  Here are some of the common problems:

• Inaccurate facility diagrams & descriptions. We find that owners forget to updated this material.  Any site modifications or improvements must be reflected in the diagram & description.
• Missing state or local requirements. Unfortunately, the EPA is not the only government entity that has rules governing this area.  States and some local jurisdictions have their own requirements and often these are not included in the SPCC plan.
• Improper process for brittle fracture. Brittle fracture evaluations must be performed & a certain inspection process must be followed.
• No monitoring of heating coils. As part of many SPCC plans, proper monitoring of internal heating coils is required.
• Improper Recording of Prior Spills. Any spills occurring at the facility must be properly documented.  Many plans we review do not have documentation detailing the corrective action taken or a procedure to prevent them from happening again.
• No description as to the impact of a potential release. Most plans will require a written statement that predicts the rate of flow and total quantity of oil that could be discharged when there is equipment failure at the location.

If you are not sure you have a compliant plan, we have all the information you need for all 50 states.

We can review your existing plan for free.

Call our National SPCC Resource Center at 1-877-440-8265.

We’re standing by- waiting to help you!