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Does My Facility Need a SPCC Plan?


The U.S. Environmental Protection Agency has the responsibility to protect all U. S. navigable waters and associated shorelines against oil spills. The Oil Pollution Prevention Regulation, set forth in 1973 and part of the Clean Water Act, requires certain facilities to prepare a Spill Prevention, Control and Countermeasures (SPCC) plan.
When Do SPCC Regulations Apply?

SPCC regulations may apply if your facility meets each of the following three threshold criteria:

  • Non-transportation related.

  • Has total aboveground storage capacity more than 1,320 gallons or below ground storage capacity more than 42,000 gallons.

  • Has a reasonable potential of discharge to U. S. navigable waters and associated shorelines.

Storage, as used in the SPCC regulations, means any type of container or equipment that has the capacity to store a minimum of 55 gallons of oil. In addition to petroleum-based oil, “oil” includes non-petroleum oil, vegetable and synthetic oil, greases, animal fats, sludge and other materials mixed with oil. 

To determine whether discharge to navigable waters is possible several factors must be evaluated and include proximity to streams, wetlands, mudflats or estuaries, storm or sewer lines, potential extreme weather conditions in your area, topography, drainage characteristics, and soil types.

What Are Non-Transportation Related Facilities?

The following are some examples of non-transportation related facilities:

  • Fixed or mobile onshore and offshore oil well drilling facilities.

  • Fixed or mobile onshore and offshore oil production facilities.

  • Oil refining or storage facilities.

  • Any facility that uses, explores for, produces, stores, consumes, refines or collects oil or oil products.

  • Certain waste treatment facilities.

  • Loading areas, transfer and other equipment that is part of a non-transportation related facility.

  • Road vehicles, rail cars or pipelines used for transportation of oil totally inside a non-transportation related facility.

This list is not comprehensive; other types of facilities may also be subject to SPCC regulations.

What Does Preparation Of A SPCC Plan Entail?

Preparation of SPCC plans is the responsibility of the facility owner; plans must be facility-specific and be certified by a registered Professional Engineer. Some facilities may qualify as Tier I or Tier II facilities to follow streamlined requirements including self-certification of facility SPCC plans.

A SPCC plan must provide detailed information about the facility and its approach to spill prevention and countermeasures. This information includes facility contacts, security, a list and description of oil-related structures, types of spills that may occur, training and spill prevention procedures, spill event containment procedures, and follow-up assessment and reporting. The SPCC plan must adhere to good engineering practice and must be well-tailored for the specific facility.

If your facility is similar to one of those listed above, you may need an SPCC plan. Contact Talon/LPE to assist in determining if you are subject to the EPA SPCC rules.

Topics: Spill Management, SPCC