Spill Control & Countermeasures Plans (SPCC)

What is an Spill Control & Countermeasures Plan?

The U.S. Environmental Protection Agency requires that certain facilities develop and implement oil spill prevention, control, and countermeasure, or SPCC Plans. Unlike oil spill contingency plans that typically address spill cleanup measures after a spill has occurred, SPCC plans ensure that facilities put in place containment and other countermeasures that would prevent oil spills that could reach navigable waters. Under EPA's Oil Pollution Prevention regulation, facilities must detail and implement spill prevention and control measures in their SPCC Plans. A spill contingency plan is required as part of the SPCC Plan if a facility is unable to provide secondary containment (e.g., berms surrounding the oil storage tank). In short, the plan must describe how you intend to operate your facility to prevent spills and what you will do to deal with them if they occur.

Does Your Facility Need A Spill Control & Countermeasures Plan?

In 1973, EPA issued the Oil Pollution Prevention Regulation, which is codified at 40 CFR Part 112, to address the oil spill prevention provisions contained in the Clean Water Act of 1972. The regulation forms the basis of EPA's oil spill prevention, control, and countermeasures, or SPCC, program, which seeks to prevent oil spills from certain aboveground and underground storage tanks. In particular, the regulation applies to non-transportation-related facilities that:

• Have an aggregate storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons; and
• Could reasonably be expected to discharge oil in harmful quantities into navigable waters of the United States.

The regulation requires each owner or operator of a regulated facility to prepare an SPCC Plan. The Plan is required to address the facility's design, operation, and maintenance procedures established to prevent spills from occurring, as well as countermeasures to control, contain, clean up, and mitigate the effects of an oil spill that could affect navigable waters.

What Does the SPCC Plan Include?

Each SPCC Plan must be unique to the facility. Development of a unique SPCC Plan requires detailed knowledge of the facility and the potential effects of any oil spill. Each SPCC plan, while unique to the facility it covers, must include certain standard elements to ensure compliance with the regulations. An SPCC Plan should include the following information and should follow the sequence outlined below:

• A facility which has experienced one or more spill events within twelve months prior to the effective date of this part should include a written description of each such spill, corrective action taken, and plans for preventing recurrence (112,7(a)).
• A prediction of the direction, rate of flow, and total quantity of oil that could be dischared where experience indicates a potential for equipment failure.
• A description of containment and/or diversionary structures or equipment to prevent discharged oil from reaching navigable waters. (For on-shore facilities, one of the following should be used as a minimum: dikes, berms, or retaining walls; curbing; culverting, gutters, or other drainage systems; weirs, booms, or other barriers; spill diversion ponds; retention ponds; sorbent materials.)
• Where appropriate, a demonstration that containment and/or diversionary structures or equipment are not practical and a strong oil spill contingency plan and a written commitment of manpower, equipment, and materials to quickly control and remove spilled oil.
• A complete discussion of the spill prevention and control measures applicable to the facility and/or its operations.

What Can DuBois & King Inc. Do To Help You?

DuBois & King, Inc., is a professional services firm staffed by scientists and environmental engineers who understand the Federal regulations (as well as applicable State regulations) and are skilled in the management of hazardous materials. We can help you fulfill each of the three major obligations under the Federal Law 40 CFR 112:

1. Preparation of an SPCC plan where none exists: site visit; review of client and State records; collection of information on equipment and instrument systems, personnel training, and safety equipment; preparation of site plan; writing of SPCC plan document; certification of plan by registered Professional Engineer.
2. Independent 3-year review of existing SPCC plan: site visit to review facilities, review of operating records, state file review, review of existing plan, recommendation of potential improvements.
3. Amendment and certification of a plan if the facility has significantly changed: site visit to review new or modified equipment; review of existing plan; updating of written portion of plan; revisions as required to existing site mapping or plans; certification of the amended plan by a registered Professional Engineer; preparation of letter to you describing the deficiencies we observed and presenting our recommendations.

Need More Information?

To learn more about what DuBois & King, Inc. can do to help you with your Spill Prevention Control & Countermeasures Plans please contact us.

For more information on the Spill Prevention Control and Countermeasure (SPCC) Rule visit the United States Environmental Protection Agency's Oil Program webpage.

References:

U.S. Environmental Protection Agency, Spill Prevention Control and Countermeasure, U.S. EPA Oil Program, Last modified 2003.01.28, United States Environmental Protection Agency, http://www.epa.gov/oilspill/spcc.htm

U.S. Environmental Protection Agency, Required Elements of Spill Prevention Control and Countermeasures Plans, U.S. EPA Oil Program, Last modified 2003.01.28, United States Environmental Protection Agency, http://www.epa.gov/oilspill/spccmust.htm

U.S. Environmental Protection Agency, Oil Pollution Prevention Regulation Overview, U.S. EPA Oil Program, Last modified 2003.01.28, United States Environmental Protection Agency, http://www.epa.gov/oilspill/opprover.htm

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