The United States Environmental Protection Agency (EPA) oil spill prevention program includes two significant rules. The first is the Spill Prevention, Control, and Countermeasure (SPCC) rule, and the second is the Facility Response Plan (FRP) rule.
In this article, we’ll give you an introduction to the EPA’s Spill Prevention, Control, and Countermeasures (SPCC) rule. Watch our future publications for a similar article about the Facility Response Plan (FRP) rule.
In addition to the two rules listed above, there’s also the Clean Water Act and the Oil Pollution Act. Again, we’ll cover those in later blog posts, so please stay tuned.
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The EPA’s Spill Prevention, Control, and Countermeasure (SPCC) rule was created to help facilities prevent a discharge of oil into navigable waters or adjoining shorelines.
The reason for this is simple: any oil spill, including an oil spill into waters or onto shorelines, can endanger public health and the health of plants and animals. Plus, cleanup of the oil spill and disposal can cost a lot of money (easily into the millions of dollars).
The SPCC regulation is actually part of the Clean Water Act (also enforced by the EPA).
According to the EPA, the SPCC regulation sets forth requirements for:
The SPCC regulation does this by requiring facilities to develop and implement Spill Prevention, Control, and Countermeasure (SPCC) Plans. It also establishes procedures, methods and equipment requirements in Subparts A, B, and C.
The SPCC requires every facility to have a spill prevention, control, and countermeasure plan. According to the EPA. for these purposes a facility is:
…any mobile or fixed, onshore or offshore building, structure, installation, equipment, pipe, or pipeline used in oil well drilling operations, oil production, oil refining, oil storage, or waste treatment.
In addition to the requirement above, to be covered by the SPCC a facility must have an aboveground aggregate oil storage capacity greater than 1,320 gallons or an underground aggregate oil storage greater than 42,000 gallons. There also be a reasonable expectation of oil discharge into or upon navigable waters or adjoining shorelines.
Certain other facilities, including some farms, are also required to develop an SPCC plan.
Every facility regulated by the SPCC has to create its own facility-specific plan. This facility-specific SPCC Plan must be prepared according to good engineering practices and must be certified by a Professional Engineer (PE). In some case, the owner or operator of the facility can choose to self-certify.
Because every facility will have its own unique SPCC plan, no two SPCC plans are the same. However, the EPA and the SPCC regulation requires that each SPCC plan contain:
The contact information for the Facility Response Coordinator, as well as any of the facilities that must be contacted in case of a spill, are listed in each facility’s SPCC plan.
The EPA requires that all SPCC-regulated facilities make their SPCC plans easily accessible. If a facility operates an aboveground storage tank for more than four hours in a day, then the SPCC plan must be kept at the facility. If a facility does not operate an aboveground storage tank for more than four hours in a day, then they may keep it at the nearest field office.
In either case, the SPCC plan must be available during normal working hours for review and inspection purposes.
The SPCC rule covers any kind of oil. This includes but is not limited to:
Here’s a rule of thumb for you: If there’s a sheen to the liquid, it’s oil covered by the SPCC rule.
There are several common types of containers and equipment that can contain oil at a facility. These include:
| Container and/or Equipment | Description |
|---|---|
| Bulk Storage Tanks | Any tanks or containers used to store oil for any reason, including prior to use, during use, or prior to commercial distribution. |
| Aboveground Storage Tanks | Bulk storage tanks that are located entirely aboveground, partially buried, bunkered, or in an underground vault or chamber. |
| Bunkered Tanks | Bulk storage tanks that are either partially located below ground level and covered with dirt, or completely aboveground and covered with dirt. |
| Underground Storage Tanks | Storage tanks that are located completely below ground level and covered with dirt. |
| Breakout Tanks | Tanks or containers used to relieve oil surges in a pipeline or to receive and store oil that will later be re-injected into a pipeline system. |
| Temporary Tanks | Tanks or containers brought into a facility for temporary use by contractors or by vendors. |
| Oil-Filled Equipment | Tanks or containers brought into a facility for temporary use by contractors or by vendors. |
Each SPCC plan must contain a site-specific facility diagram.
The facility diagram is used to show the topography of the site as well as the location of the facility in relation to waterways, roads, and inhabited areas. The facility diagram also illustrates the:
The facility diagram should be easy to read and should include no unrelated information or diagrams.
Every facility regulated by SPCC must designate a Facility Response Coordinator. The Facility Response coordinator is accountable for the overall spill prevention and response procedures.
The Facility Response Coordinator is responsible for conducting Spill Prevention Briefings at least once a year to ensure the adequate understanding and effective implementation of the SPCC plan. These briefings describe the known spill events or failures, malfunctioning components, and recently developed precautionary measures.
All the images in this blog post, and much of the information, were taken from our online Spill Prevention, Control, and Countermeasures training course (which is itself part of our online environmental compliance training library). Check the links in the previous sentence and/or watch the short video sample below from our online SPCC course.
We hope you found this overview of the EPA’s Spill Prevention, Control, and Countermeasures regulation helpful. Let us know if you have any questions and have a great day!
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