Trinity Consulting Services: SPCC planning
For over 30 years, Trinity has developed SPCC plans for numerous industrial facilities nationally and can also assist with plan revisions and program audits. Our services include but are not limited to:
- Plan preparation
- Plan review
- Plan execution (employee training, inspection, monitoring)
- Compliance audits
- Secondary containment evaluation
What is a Spill Prevention, Control, and Countermeasure plan?
SPCC plans ensure that facilities have in place containment and other controls that would prevent oil from reaching navigable waters and adjoining shorelines, and to contain discharges of oil should a spill occur.
While each SPCC plan is unique to the facility it covers, it must include the following elements:
- Facility Diagram indicating oil related activities
- Description of each oil container
- Prediction of the flow direction
- Predicted rate of flow
- Quantity of oil that could be released
- Description of containment and/or diversionary structures
- Oil handling & spill prevention procedures
- Spill Reporting procedures
- Spill Response procedures
- Inspection & Monitoring procedures
- Integrity testing
- Employee training
A copy of the SPCC plan must be kept at any facility that is open at least four hours per day; otherwise it must be kept at the nearest field office. The SPCC plan must be available to EPA for onsite review and inspection during normal working hours, include a demonstration of management approval, and in many cases, be certified by a registered professional engineer of the state.
Every five years
Spill Prevention, Control, and Countermeasure (SPCC) plans must be reviewed and evaluated at least once every five years to consider more effective prevention and control technology. Typically, if you have made necessary changes (including changes to site contacts, ownership transfers, etc.), there are no significant updates needed during review time. Most facilities will need to complete this review in 2019 or 2020.
SPCC plan revisions are required as soon as possible, but not to exceed six months of making a technical amendment. After the plan has been revised to reflect a change, requirements must be implemented as soon as possible, but no later than six months following an amendment.
The Oil Pollution Prevention regulation promulgated under the Federal Clean Water Act regulation at 40 CFR part 112 addresses the SPCC requirements. The SPCC rule was promulgated in 1973, with significant amendments published in 2002. EPA finalized additional revisions in 2006, 2008, 2009, and 2011 to address compliance dates and tailor specific regulatory requirements.
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, hydraulic oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil. There is no de minimis concentration for oil mixtures.
EPA's oil spill prevention program includes two parts:
- Spill Prevention, Control, and Countermeasures (SPCC) rule: helps facilities prevent a discharge of oil into navigable waters or adjoining shorelines
- Facility Response Plan (FRP) rule: requires certain facilities to submit a response plan and prepare to respond to a worst case oil discharge or threat of a discharge
Who needs to develop a SPCC plan and what must be considered?
The Clean Water Act contains provisions requiring facilities that could reasonably be expected to discharge oil (or petroleum products) in harmful quantities into or upon navigable U.S. waters to prepare an SPCC plan. In general, facilities are subject to SPCC rule requirements if they:
- Are non-transportation-related
- Have an aboveground oil capacity of more than 1,320 gallons on site, or underground oil capacity of 42,000 gallons counting containers 55 gallons and larger based on shell capacity, and
- Could reasonably be expected to discharge oil to navigable waters or adjoining shorelines in quantities that may be harmful
During a SPCC Plan Review, it is a good time to consider auditing and possibly upgrading your plan. Questions to ask regarding your plan include, but are not limited to:
- Are your plans consistent across the company?
- Does it make sense to combine your SPCC plan with other environmental and/or operational plans?
- Have there been any changes in that were not captured in prior amendments (i.e., removal, addition, or relocation of oil-filled equipment, non-replacement in-kind, new tanks or container storage, new contents)?
- Have your secondary containments changed since the last renewal?
- This is especially important where earthen berms are used for containment. Erosion must be considered, and containment capacity should be re-calculated.
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- SPCC Plan Reviews - Not Just a Rubber Stamp -- May 30, 2019