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Oil Spills and Water Do Not Mix: Guidance for Company SPCC Plans

Posted on Thu, Jul 02, 2015

Most analogies regarding oil and water convey an image of chaotic polarity. If oil comes in contact with water in an industrial setting, it can be destructive and costly. Oil spills that discharge into waterways have adversely affected environments and wildlife, caused substantial economic losses to communities, and inflicted financial penalties on companies.

If a company is subject to the Environmental Protection Agency’s Spill Prevention, Control, and Countermeasure (SPCC) rule, they must ensure plans are established, accurate, and compliant. The EPA estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the following rule:

A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires these plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.

Since 1974, owners and operators of certain oil-handling facilities have been subject to the regulation. When referring to a recently plan delinquent and fined rail facility, the EPA stated that the failure to “maintain and fully implement an adequate SPCC plan leaves a facility unprepared to deal with an oil spill and to prevent a spill from having potentially serious consequences.”

Compliant "spill prevention" plans can prevent spills from occurring, as well as speed up necessary response and recovery actions. For EPA compliance, plans should provide site-specific details that allow responders to best access, assess, and quickly respond to off-site spills, limiting the effects of a spill on sensitive environments. The plans also relay site specific information related to the storage and management of oil. These plans require that facilities identify sufficient containment and/or other applicable countermeasures to reduce the potential for oil spills to reach navigable waters.


Typical elements of an SPCC Plan include:

  • Professional Engineer Certification
  • Discussion of conformance with federal regulations
  • Facility description, plot plan, and contacts
  • Potential spill volume and flow rates
  • Inspections, tests and record keeping processes
  • Personnel training requirements
  • Loading/Unloading and transfer details
  • Discharge prevention measures
  • Security Measures
  • Recovered material drainage and disposal methods
  • Bulk Storage tanks details
  • Secondary containment locations and volumes
  • Discharge notification information and procedure
If a facility has more than 10,000 gallons of aggregate aboveground oil storage capacity, the plan must be inspected and certified by a professional engineer (PE). The certifying engineer must:
  • Be familiar with plan requirements
  • Visit applicable site and examine the facility
  • Certify that the plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards
  • Confirm that procedures for required inspections and testing have been established
  • Certify that the plan is adequate for the specific facility

Facilities that require these plans, yet have an aboveground oil storage capacity of less than 10,000 gallons, may self-certify these plans if they meet the following criteria;

The facility must not have had

  1. A single discharge of oil to navigable waters exceeding 1,000 U.S. gallons
  2. Two discharges of oil to navigable waters each exceeding 42 U.S. gallons within any twelve-month period, in the three years prior to the SPCC Plan certification date, or since becoming subject to Title 40, Part 112 of the Code of Federal Regulations (CFR) if facility has been in operation for less than three years.

If a facility owner meets the above criteria, then the company may;

  • Prepare a self-certified plan
  • Meet tailored facility security and tank integrity inspection requirements without PE certification
  • Prepare a Plan which includes required PE certification for only the portions dealing with environmental equivalence and impracticability determinations. The remaining portions of the plan could be self-certified by the facility owner/operator.


Tags: SPCC