The purpose of an SPCC Plan is to form a comprehensive spill prevention program that minimizes the potential for oil discharges to the environment.
What is Oil?
Oil is defined as, “oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil,” in 40 CFR 112.2.
Who is required to develop an SPCC Plan?
The SPCC or oil pollution prevention regulations, 40 CFR Part 112, apply to any facility engaged in drilling, producing gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products (including fuel).
A facility that meets the above description AND has a total aboveground storage capacity greater than 1,320 gallons OR total underground storage capacity greater than 42,000 gallons is required to develop and implement a SPCC Plan.
How to determine your facility’s applicability:
Locate any SPCC regulated equipment on-site, such as:
- Bulk Oil Storage Containers
- Bulk oil storage containers are containers with capacities greater than or equal to 55 gallons.
- Portable containers are included (i.e., drums, totes, etc.).
- Oil-Filled Operational Equipment
- Equipment that includes an oil storage container (or multiple containers) that are greater or equal to 55 gallons, and oil is present SOLELY to support the function of the apparatus or device is oil-filled operational equipment. Examples include but are not limited to hydraulic oil systems and transformers.
- Loading/Unloading Rack
- It is a fixed structure (such as a platform or gangway) necessary for loading or unloading a tank truck or tank car.
- A loading/unloading rack includes a loading or unloading “arm”, and may include any combination of piping, valves, pumps, shut-off devices, overfill sensors, or personnel safety devices.
- Transfer Areas (not associated with a loading/unloading rack)
- It is any area where oil is transferred between bulk storage containers and tank trucks or railroad cars other than a loading/unloading rack.
- Add the storage capacities of all bulk oil storage containers and oil-filled operational equipment that is greater than or equal to 55 gallons. If the total is greater than 1,320 gallons for aboveground storage or 42,000 gallons for underground, your facility is subject to SPCC regulations.
Requirements for applicable facilities:
- Develop and implement an SPCC Plan with a Professional Engineer’s (P.E.) signature
- Update the plan at least annually and recertify every 5 years
- Recertification requires a P.E.’s signature
- Perform monthly inspections of all SPCC regulated equipment
- Perform annual inspections for all aboveground storage tanks in accordance with the Steel Tank Institute’s (STI) Standard for inspection.
- Depending on the tank type and size, perform formal external or internal inspections by a certified inspector.
- Train facility personnel annually on SPCC requirements
- Provide passive containment (i.e., dikes, spill pallets, drip pans, sumps, etc.) for all bulk oil storage containers greater than or equal to 55 gallons and loading/unloading racks.
- Provide active containment (i.e., spill kits) for qualifying oil-filled operational equipment and transfer areas.
- Notify the Regional Administrator of the Environmental Protection Agency (EPA) for a discharge greater than 1,000 gallons or any two (2) discharges over a twelve (12) month period of more than 42 gallons per event.
How ECS can assist your facility!
- ECS has certified inspectors for formal tank inspections
- ECS has professional engineers to certify and develop SPCC Plans
- ECS can help your facility determine if an SPCC Plan is required, and how to comply with the SPCC regulations.
For questions regarding SPCC Regulations or if you would like assistance with your facility, contact Environmental Compliance & Safety at:
- Phone: (662) 840-5945
- Website: https://envirocomp.net/contact/
