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The SPCC and Oil Spill Prevention - May 2017
Using oil at your facility can represent a risk for the
environment and a hazard to your workers as well as your property. The
Environmental Protection Agency (EPA) regulates facilities’ spill-prevention
measures with the Oil Spill Prevention, Control and Countermeasure (SPCC) Rule,
which sets specific requirements for facilities that meet certain criteria
regarding the risk of spills. The regulation specifies actions required for the
prevention of, preparedness for and response to oil discharges. According to
recent modifications to the rule, all covered facilities must prepare and
implement a SPCC Plan. To ensure you are in compliance, review the following
To Whom Does the SPCC Apply?
A facility is covered by the SPCC rule if it fulfills the
- It has a total aboveground oil storage capacity greater than
- It stores, transfers, uses or consumes oil or oil products
including diesel fuel, gasoline, lube oil or hydraulic oil.
- It could reasonably be expected to discharge oil to waters
of the United States or adjoining shorelines, such as interstate waters,
intrastate lakes, rivers and streams.
Those with operations on multiple pieces of property need
not combine the number of containers on separate properties for the purposes of
this rule. In fact, if you identify adjacent pieces of property as separate
based on operations, you can advantageously count the containers on the two
What Does the SPCC Rule Require?
If the rule applies to your property, you are required to
prepare and implement an SPCC Plan or adequately maintain your plan if you
already have one. You need not submit the plan to the EPA unless it is
requested, but you should maintain the plan at the facility. Your
responsibilities include the following:
1. Prevent oil spills. Following are some prevention measures
that could be included in your plan.
- Use containers that are appropriate for the oil stored. For
example, use a container designed for flammable liquids to store gasoline.
- Provide overfill prevention (e.g., high-level alarms or
audible vents) for oil storage containers.
- Provide secondary containment for bulk storage containers,
such as a dike or remote impoundment. It must hold the container’s full capacity plus
possible rainfall. The dike may be constructed of earth or concrete, e.g., a
- Provide general secondary containment (e.g., sorbent materials,
drip pans and curbing) to catch the most likely oil spill, where oil is transferred
to and from containers and for mobile refuelers and tanker trucks.
- Inspect and test pipes and containers regularly. Visually
inspect aboveground pipes and oil containers according to industry standards,
and test buried pipes for leaks when they are installed o repaired.
2. Prepare and implement a SPCC Plan. The owner or operator of
the facility must develop and implement a SPCC Plan that describes oil handling
operations, spill prevention practices, discharge or drainage controls, and the
personnel, equipment and resources at the facility that are used to prevent oil
spills from reaching navigable waters or adjoining shorelines. Each SPCC Plan
is unique to the facility, but there are certain elements that must be detailed
in every plan, including the following:
- Operating procedures used to prevent oil spills at the
- Control measures (e.g., secondary confinement) installed to
prevent oil spills from entering navigable waters or adjoining shorelines.
- Countermeasures to contain, clean and mitigate the effects
of an oil spill that has impacted navigable waters or adjoining shorelines.
Certifying the Plan
If your facility meets the following criteria, you may be
eligible to self-certify your SPCC Plan.
- Aboveground oil storage capacity of 10,000 gallons or less
- No discharge of more than 1,000 gallons of oil to navigable
waters or adjoining shorelines in the last three years, or no two discharges
more than 42 gallons in the last 12-month period.
If you are not eligible to self-certify, your plan must be
certified by a licensed professional engineer (PE), who will confirm the
- Familiarity with the requirements of the rule
- Visit and examination of the facility
- SPCC Plan in accordance with good engineering practices,
including consideration of applicable industry standards and requirements of
- Existence of procedures for required inspections and testing
- Adequacy of the SPCC Plan for the facility
In Case of Spill
If your facility experiences a spill, you are required to
follow certain federal reporting requirements. Anyone in charge of an onshore
or offshore facility must notify the National Response Center (NRC) immediately
after receiving notice of the discharge. You will need the following
- Name and location of facility
- Owner/operator name
- Maximum storage/handling capacity of the facility and normal
- Corrective actions and countermeasures taken, including
equipment repairs or replacements
- Adequate description of the facility, including maps, flow
diagrams and topographical maps
- Cause of the discharge to navigable waters, including a
- Failure analysis of the system where discharge occurred
- Additional preventive measures taken or planned to take to
minimize discharge reoccurrence
It is important to know that you must also comply with state
and local reporting requirements. It often makes sense to call 911 when there
is an oil spill, especially if it is flammable or combustible.
You must also report spills to the EPA when one of the
- More than 1,000 gallons of oil is discharged to navigable
waters or adjoining shorelines in a single event
- More than 42 gallons of oil in each of two discharges to
navigable waters or adjoining shorelines occurs within any 12-month period.
Mitigating Your Risk Through Risk Management
Experiencing an oil spill can be devastatingly expensive. In
addition to ensuring compliance through the development of an SPCC Plan, work
with the insurance professionals at CMR Risk & Insurance Services, Inc. to
ensure you have purchased appropriate insurance coverage.