Developing an SPCC Plan

Part of the Clean Water Act, the Oil Pollution Prevention (OPP) standards at 40 CFR 112 require certain facilities to develop a plan “to prevent the discharge of oil from non-transportation-related, onshore and offshore facilities into or upon the navigable waters of the United States or adjoining shorelines.” [40 CFR 112.1(a)(1)]

Called an Spill Prevention, Control, and Countermeasure Plan (SPCC Plan), it details the equipment, personnel, procedures, and steps a facility will take to control and counter discharges of oil to the environment. 

SPCC Plans are required for facilities that store, drill for, produce, gather, process, refine, transfer, distribute or otherwise use oil, and from which a release could reach the waters of the United States.

• More than 42,000 underground storage capacity; or
• More than 1,320 of above ground storage capacity, excluding containers less than 55 gallons.

Oil means 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.

Secondary containment is a level of spill prevention beyond the container itself. While the container prevents immediate spills, secondary containment — when required — is in place in case the container fails, overflows, tips over, or otherwise releases oil or hazardous substances.

EPA requires a Facility Response Plan (FRP) for any facility that could reasonably be expected to have a release of oil to the navigable waters of the United States that causes substantial harm to the environment. In general, a Facility Response Plan is required when one of the following conditions is true:

• Your site’s total oil storage capacity is greater than or equal to 1 million gallons.

• Your facility transfers oil over water to or from vessels and has a total oil storage capacity greater than or equal to 42,000 gallons.

• ​Your facility is notified by your EPA Regional Administrator that an FRP is required “because EPA says so.” 

If you determine that your facility is required to maintain an SPCC Plan, any employee with responsibilities under the plan should be trained to competently and properly carry out his or her responsibilities under the plan.

Depending on your facility, Facility Response Plans (FRPs) may require emergency preparedness exercises, drills, or regular/annual re-training to keep covered employees’ knowledge and skills sharp.

• Identify US EPA SPCC Plan requirements that apply to your facility or operation
• Develop expertise to create an SPCC plan and maintain compliance

• Background of the Clean Water Act and SPCC Plans
• How to create and certify an SPCC Plan
• How to identify “Waters of the United States” (WOTUS)
• Key exclusions from the SPCC Plan requirements
• Requirements for discharge prevention measures and control
• How to select the right secondary containment controls
• SPCC facility inspection and testing requirements
• PE certification versus self-certification
• How to deal with releases
• What’s in a Facility Response Plan (FRP) and when it’s required
• Employee training requirements for SPCC plans and Facility Response Plans

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