SPCC Plans: What Are They and Does Your Company Need One?
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If your company uses or stores large quantities of oil, you may be subject to EPA’s Spill Prevention, Control and Countermeasures, or SPCC regulation and be required to have a plan to prevent discharges of that oil into navigable waters.
⚡ TL;DR: SPCC regulations require facilities with 1,320+ gallons of aboveground oil storage (or 42,000+ gallons underground) to have a documented spill prevention and response plan. Without one, you face EPA enforcement action, cleanup liability, and potential environmental damage liability.
Who Needs to Comply with SPCC?
SPCC regulations cover all types of oils, including petroleum, fuel oil, sludge, vegetable oils, mineral oils and synthetic oils. If your facility has the capacity aboveground of 1,320 gallons or more or underground capacity of 42,000 gallons or more, you quality for this regulation.
To count capacity, add together everything that can store 55 gallons or more of petroleum. This includes drums, totes, tanks, or any other storage vessel. Also included in the total is the capacity from equipment such as hydraulic systems, lubricating systems, gear boxes, coolant systems, heat transfer and transformers, circuit breakers and electrical switches.
Therefore, all types of industries are included within this regulation, including, but not limited to:
Industrial and Commercial Facilities Using or Storing Oil Oil Exploration and Production Refining and Storage Airports Marinas Power Transmission, Generation and Distribution Construction Waste Treatment
⚠️ What’s at stake: Oil discharges into navigable waters (which includes storm sewers, ditches, and streams) trigger EPA civil penalties of up to $25,000+ per day of violation. Beyond penalties, your facility becomes liable for environmental remediation costs, natural resource damages, cleanup, and regulatory enforcement actions that can total millions of dollars.
What’s the Purpose of SPCC?
SPCC planning is the practices, procedures, structures, and equipment used at the facility to prevent spills from reaching and contaminating navigable waters. Most facilities will discharge to navigable waters because this often includes ditches, storm sewers, and other drainage systems that can lead to streams, creeks and other bodies of water.
SPCC planning includes three basic functions: 1) Practices devoted to the prevention of spills, 2) Planning for containments should a spill occur, and 3) Removal, cleanup, and disposal of spilled materials. These basic functions are incorporated into the SPCC Plan.
What’s Included in an SPCC Plan?
A SPCC Plan has several required elements, including:
Petroleum-related chemical quantities and locations; Release prevention structures; Release prevention procedures; Procedures in place to respond to a spill, should it occur; Equipment used to prevent or respond to a spill; Key personnel; Training programs; Spill history; and, Certification.
In most cases, the certification of the SPCC Plan needs to be completed by a professional engineer.
Compliance Deadlines
If you make changes to your facility, such as adding containers, secondary containment structures, or installation of piping, you must update your SPCC Plan within six months of the change.
Per requirements, review your SPCC Plan every 5 years and make changes accordingly.
Where Do You Send the SPCC Plan?
Unless you’re asked for it, your plan stays onsite and is not required to be submitted to EPA or your state office. Some states do have SPCC requirements in addition to the EPA requirements.
EPA says that if the facility the SPCC Plan covers is staffed at least 4 hours per day, the Plan needs to be maintained there. If the facility is not staffed 4 hours per day, then it can be maintained at the nearest field office.
Does your facility store or use petroleum products above the SPCC threshold? iSi’s environmental specialists help industrial and manufacturing facilities develop, update, and certify SPCC plans that prevent spills, demonstrate EPA compliance, and protect your water resources and operations. Get started →
Frequently Asked Questions
Q: What is an SPCC plan and why is it required?
A: SPCC (Spill Prevention, Control and Countermeasures) is an EPA requirement for facilities storing or using petroleum products. SPCC plans establish practices, procedures, structures, and equipment to prevent oil spills from reaching navigable waters, which include ditches, storm sewers, streams, and other drainage systems.
Q: Which facilities are subject to SPCC requirements?
A: SPCC applies to facilities with aboveground oil storage capacity of 1,320 gallons or more, or underground capacity of 42,000 gallons or more. This includes industrial facilities, refineries, airports, marinas, construction sites, and any operation using oils (petroleum, fuel, vegetable, mineral, synthetic) or equipment with hydraulic systems, gear boxes, transformers, or coolant systems.
Q: What elements must be included in an SPCC plan?
A: Required SPCC plan elements include petroleum chemical quantities and locations, release prevention structures and procedures, response procedures for spills, equipment for spill prevention and response, key personnel identification, training programs, spill history, and professional engineer certification. Plans must include prevention, containment, and cleanup procedures.
Q: How often must SPCC plans be reviewed and updated?
A: SPCC plans must be reviewed every 5 years and updated accordingly. Any facility modifications (adding containers, secondary containment, piping) require SPCC plan updates within 6 months. Plans are maintained onsite at staffed facilities and at the nearest field office for unstaffed locations, and do not need submission to EPA unless requested.
💰 The cost of non-compliance: EPA civil penalties for SPCC violations reach $25,000+ per day of non-compliance. Oil discharge incidents trigger environmental cleanup costs, natural resource damage assessments, and regulatory enforcement that regularly exceed $500,000 for moderate spills and can reach millions for significant incidents. Uncontained spills to navigable waters also create criminal liability.
Every facility with oil storage or use above SPCC thresholds needs a compliant, current plan. iSi Environmental helps industrial and manufacturing facilities develop SPCC plans that meet EPA requirements, prevent spills, and protect your operations and environment. Schedule an SPCC assessment →
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