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An SPCC (Spill Prevention, Control, and Countermeasure) plan is a document required by the U.S. Environmental Protection Agency (EPA) for certain facilities that store, use, or handle oil in quantities that could potentially harm the environment if released into navigable waters or adjoining shorelines. The SPCC plan outlines measures and procedures aimed at preventing oil spills, as well as strategies for controlling and mitigating the impacts of any spills that may occur.
Key points about SPCC plans and whether you need one:
Regulatory Requirement: The need for an SPCC plan is a regulatory requirement under the Clean Water Act (CWA) and is enforced by the EPA. It is designed to protect water resources from the harmful effects of oil spills.
Facility Thresholds: You need an SPCC plan if your facility meets certain thresholds for oil storage. Specifically, you must have an SPCC plan if your facility:
- Has an aggregate aboveground oil storage capacity of 1,320 gallons or more; or
- Has a completely buried oil storage capacity of 42,000 gallons or more.
Exemptions: Some facilities are exempt from the SPCC rule. These exemptions include facilities that store oil exclusively for on-site heating, non-transportation-related oil-filled equipment, and facilities with a total oil storage capacity less than 10,000 gallons if no single container has a capacity of 5,000 gallons or more.
SPCC Plan Components: An SPCC plan typically includes:
- Description of the facility and its operations.Inventory of oil storage containers and equipment.
- Procedures for preventing oil spills.
- Procedures for controlling and mitigating spills.
- Training and certification of personnel.
- Regular inspection and maintenance schedules.
Recordkeeping requirements.
Certification: The SPCC plan must be certified by a Professional Engineer (PE).
Regular Review and Updates: SPCC plans must be reviewed and updated periodically to account for changes in facility operations, equipment, or regulations.
Enforcement: Failure to comply with the SPCC regulations can result in penalties and fines imposed by the EPA.
The EPA requires the following containers, with a capacity of 55 gallons or more, to be subject to integrity testing and routinely inspected:
- Large (field-constructed or field-erected) and small (shop-built) bulk storage containers;
- Containers located on, partially in (partially buried, bunkered, or vaulted tanks), and off the ground wherever located; and
- Double-walled containers.
Oil-filled equipment is not a bulk storage container and, therefore, not subject to the integrity testing requirements of the SPCC rule.
The SPCC rule requires that you:
- Test or inspect each container for integrity on a regular schedule and whenever you make material repairs; and
- Frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. This visual inspection is intended to be a routine walk-around and includes the container’s supports and foundations.
- Identify in your SPCC Plan the type and frequency of testing and inspection for each container and the appropriate qualifications of personnel performing the tests and inspections. You must retain testing and inspection records for 3 years. EPA recommends that formal test records or reports be retained for the life of the container.
Depending on the type of container, integrity testing may be as simple as an external visual inspection or may involve more complicated methods of non-destructive testing that will require the expertise of certified trained inspectors.
For example, integrity testing of field-erected above-ground storage tanks following API 653 involves formal in-service external inspections and formal out-of-service internal inspections to be conducted by an API 653 certified inspector. Formal inspections can involve MFL scanning of the floor, vacuum box testing floor welds, helium leak testing, UT measurements, and tank bottom settlement measurements.
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