Does My Facility Need an SPCC Plan?
Posted on April 16, 2024
If you operate a facility that deals with oil or oil products, understanding whether you need a Spill Prevention, Control, and Countermeasure (SPCC) plan is crucial. Let’s break down the key criteria to determine if your facility is covered by SPCC regulations.
SPCC regulations apply to facilities that meet the following criteria:
1. Oil Handling: Your facility stores, transfers, uses, or consumes oil or oil products. This includes substances like diesel fuel, gasoline, lube oil, hydraulic oil, and more.
2. Storage Capacity: Your facility stores more than 1,320 U.S. gallons in total of all aboveground containers, considering only containers with a storage capacity of 55 gallons or greater. Alternatively, if your facility has underground containers, it must store more than 42,000 gallons.
3. Potential for Oil Discharge: Your facility could reasonably be expected to discharge oil to navigable waters of the U.S. or adjoining shorelines, such as lakes, rivers, streams, or coastal areas.
Determining the Risk of Oil Discharge
To assess whether your facility could reasonably discharge oil into navigable waters or adjoining shorelines, consider the following factors:
1. Geography and Location. Evaluate the proximity of your facility to nearby water bodies and drainage systems, such as ditches, storm sewers, or gullies.
2. Volume and Flow. Estimate the volume of oil that could be spilled and how it might drain or flow from your facility, considering soil conditions and geographic features that could affect the flow towards waterways.
3. Precipitation Runoff. Assess whether precipitation runoff could transport oil into navigable waters or adjoining shorelines.
It’s essential to exclude manmade features like dikes or containment structures that might hinder the flow of oil when making this determination. If you consider the applicable factors described above and determine whether a spill can reasonably flow to a waterway, navigable water or adjoining shorelines, then you must comply with the SPCC rule.
Sources
“40 CFR Part 112 Subpart A.” Code of Federal Regulations, https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-112/subpart-A.
“Spill Prevention, Control, and Countermeasure (SPCC) for the Upstream (Oil Exploration and Production) Sector.” EPA, https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/spill-prevention-control-and-countermeasure-19.
Cover Photo: jeffy1139 – stock.adobe.com