SPCC Plans............................................................................................... Prices Quote Upon Request
Oils are defined under several statutes including the Clean Water Act (CWA) and the Oil Pollution act of
1990 (OPA). As a result overlapping regulatory interpretations exist. For this reason, the U.S. EPA and
the U.S. Coastguard are currently developing a nationally consistent program policy and methodology for
facilities to determine whether a given substance is considered an oil under CWA. Under the CWA the
definition of oil includes oil of any kind and any form such as petroleum and non-petroleum oils.
Generally, Oils fall into the following categories: crude oil and refined petroleum products, edible animal
and vegetable oil, other oils of animal or vegetable origin and other non-petroleum oils.
These regulations are in place primarily to require that facilities implement measures that will prevent and
control oil spills that may result due to human operational error or equipment failure. Facilities that are in
full compliance reduce the number and severity of discharges and do not face the high costs of
environmental cleanup or additional permitting requirements that could be imposed in the event of a
discharge..
EPA’s SPCC requirements (40 CFR 112.1 through 112.7) apply to non-transportation related fixed
facilities that could reasonably be expected to discharge oil into or upon the navigable waters of the
United States or adjoining shorelines, and that have (1) an above ground oil storage capacity of more
than 660 gallons in a single container, or (2) a total aboveground oil storage capacity of more than 1320
gallons or (3) a total underground buried storage capacity of more than 42,000 gallons. The
requirements apply specifically to a facility’s storage capacity, regardless of whether the tanks are
completely filled.
The SPCC requirements (40 CFR 112.1 through 112.7) apply to facilities that meet the minimum
applicability standards to prevent oil spills from reaching the navigable waters of the U.S. or adjoining
shorelines. The SPCC Plan must describe discharge prevention structures such as secondary
containment, proper operation and maintenance at the facility, and adequate training for facility personnel.
In 1990, Congress passed the Oil Pollution Act, which amended Section 311 of the Clean Water Act to
require “substantial harm” facilities to develop and implement FRPs. Under the FRP requirements,
codified at 40 CFR 112.20 and 112.21, owners and operators of facilities that could cause “substantial
harm” to the environment by discharging oil into navigable water bodies or adjoining shorelines must
prepare and implement plans, training, and drills for responding to a worst case discharge of oil, to a
substantial threat of such a discharge and to discharge smaller than worst case discharges.
GENERAL SPCC REQUIREMENTS
The Owner or operator of a regulated facility is required to have an SPCC plan, which is a written site-
specific description detailing how a facility’s operation complies with 40 CFR Part 112. While each SPCC
Plan is unique, certain elements must be included in order for the SPCC Plan to comply with the
provisions of 40 CFR Part 112. If a section does not apply to the facility, this must be stated. These
elements include, but are not limited to the following:
1) Professional Engineer (PE) Certification
2) SPCC Plan Kept Onsite
3) Management Approval
4) Plan Sequence Follows 40 CFR Part 112
5) Spill History
6) Spill Prediction
7) Plan Review
8) Amendment by Regional Administrator
9) Secondary Containment or Contingency Plans
10) Spill Reporting
11) Performance-Based SPCC Requirements
12) Initial Screening and Certification: Determination of Response Plan Applicability
CTR will endeavor to provide commitment, direction and expertise necessary to achieve client compliancy.
The burden of responsibility for maintaining compliance with Federal, State and Local regulatory agencies
lies solely with the client.
SCOPE OF SERVICES
1) Conducting an on-site SPCC assessment by representative of CTR and a State Certified Professional
Engineer to evaluate primary and secondary containment as well as diversionary structure efficacy,
alternative containment including diked areas for water diversion and/or contamination, visual inspection
of transfer systems and valves, oil and chemical AST’s inside and outside the facility (bulk storage tanks,
portable tanks, drums and oil containing equipment (40 CFR 112.7[e][2]), examine foundations and
supports for each tank and container to assess whether adequate support is provided. We further
propose to inspect for proper transfer and tank labeling, proper design and spacing, security features for
restricting access to areas where there would be a risk of a release as well as evaluating locking devices
for controls, valves and starters.
2) Provide all the necessary documentation (reports, forms and procedures).
3) Review plan requirements with management, discuss spill history, spill prediction and remedial
activities associated with a release as well as first responder duties as they apply to the SPCC
plan.
Oils are defined under several statutes including the Clean Water Act (CWA) and the Oil Pollution act of
1990 (OPA). As a result overlapping regulatory interpretations exist. For this reason, the U.S. EPA and
the U.S. Coastguard are currently developing a nationally consistent program policy and methodology for
facilities to determine whether a given substance is considered an oil under CWA. Under the CWA the
definition of oil includes oil of any kind and any form such as petroleum and non-petroleum oils.
Generally, Oils fall into the following categories: crude oil and refined petroleum products, edible animal
and vegetable oil, other oils of animal or vegetable origin and other non-petroleum oils.
These regulations are in place primarily to require that facilities implement measures that will prevent and
control oil spills that may result due to human operational error or equipment failure. Facilities that are in
full compliance reduce the number and severity of discharges and do not face the high costs of
environmental cleanup or additional permitting requirements that could be imposed in the event of a
discharge..
EPA’s SPCC requirements (40 CFR 112.1 through 112.7) apply to non-transportation related fixed
facilities that could reasonably be expected to discharge oil into or upon the navigable waters of the
United States or adjoining shorelines, and that have (1) an above ground oil storage capacity of more
than 660 gallons in a single container, or (2) a total aboveground oil storage capacity of more than 1320
gallons or (3) a total underground buried storage capacity of more than 42,000 gallons. The
requirements apply specifically to a facility’s storage capacity, regardless of whether the tanks are
completely filled.
The SPCC requirements (40 CFR 112.1 through 112.7) apply to facilities that meet the minimum
applicability standards to prevent oil spills from reaching the navigable waters of the U.S. or adjoining
shorelines. The SPCC Plan must describe discharge prevention structures such as secondary
containment, proper operation and maintenance at the facility, and adequate training for facility personnel.
In 1990, Congress passed the Oil Pollution Act, which amended Section 311 of the Clean Water Act to
require “substantial harm” facilities to develop and implement FRPs. Under the FRP requirements,
codified at 40 CFR 112.20 and 112.21, owners and operators of facilities that could cause “substantial
harm” to the environment by discharging oil into navigable water bodies or adjoining shorelines must
prepare and implement plans, training, and drills for responding to a worst case discharge of oil, to a
substantial threat of such a discharge and to discharge smaller than worst case discharges.
GENERAL SPCC REQUIREMENTS
The Owner or operator of a regulated facility is required to have an SPCC plan, which is a written site-
specific description detailing how a facility’s operation complies with 40 CFR Part 112. While each SPCC
Plan is unique, certain elements must be included in order for the SPCC Plan to comply with the
provisions of 40 CFR Part 112. If a section does not apply to the facility, this must be stated. These
elements include, but are not limited to the following:
1) Professional Engineer (PE) Certification
2) SPCC Plan Kept Onsite
3) Management Approval
4) Plan Sequence Follows 40 CFR Part 112
5) Spill History
6) Spill Prediction
7) Plan Review
8) Amendment by Regional Administrator
9) Secondary Containment or Contingency Plans
10) Spill Reporting
11) Performance-Based SPCC Requirements
12) Initial Screening and Certification: Determination of Response Plan Applicability
CTR will endeavor to provide commitment, direction and expertise necessary to achieve client compliancy.
The burden of responsibility for maintaining compliance with Federal, State and Local regulatory agencies
lies solely with the client.
SCOPE OF SERVICES
1) Conducting an on-site SPCC assessment by representative of CTR and a State Certified Professional
Engineer to evaluate primary and secondary containment as well as diversionary structure efficacy,
alternative containment including diked areas for water diversion and/or contamination, visual inspection
of transfer systems and valves, oil and chemical AST’s inside and outside the facility (bulk storage tanks,
portable tanks, drums and oil containing equipment (40 CFR 112.7[e][2]), examine foundations and
supports for each tank and container to assess whether adequate support is provided. We further
propose to inspect for proper transfer and tank labeling, proper design and spacing, security features for
restricting access to areas where there would be a risk of a release as well as evaluating locking devices
for controls, valves and starters.
2) Provide all the necessary documentation (reports, forms and procedures).
3) Review plan requirements with management, discuss spill history, spill prediction and remedial
activities associated with a release as well as first responder duties as they apply to the SPCC
plan.
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| This page was last updated: March 30, 2009 |
