SPCC Regulations:
Applicability and Requirements
Timothy W. Kipp, CHMM
Senior Consultant
GZA GeoEnvironmental, Inc.
4 Free St
Portland, ME 04101
(207) 358-5121
timothy.kipp@gza.com
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Spill Prevention, Control, and
Countermeasures (SPCC) Rule
Federal Rule
Clean Water Act (40 CFR Part 112)
US Environmental Protection Agency
Enforced by EPA Regional Offices
– Initial SPCC Rule - 1973
– Revisions issued 2002-2009
– Compliance deadline for revised rule –
November 10, 2011!
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Applicability
• SPCC Plan required if you have:
• Aboveground oil storage capacity greater than 1,320
gallons; or
• Underground oil storage capacity greater than 42,000
gallons (not subject to 280/281 regulations); and
• Potential to release oil to navigable waters
of the US
– Only count containers 55-gallons or greater
– Includes oil-filled operational equipment
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What Oils are Covered under
the SPCC regulation?
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Oils and greases
Petroleum
Fuel oil
Mineral oils
Synthetic oils
– Heat transfer fluids, engine fluids, hydraulic and transmission
fluids, metalworking fluids, dielectric fluids, compressor
lubricants, and turbine lubricants
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Animal fats and vegetable oils
Sludge
Oil refuse
Oil mixed with wastes other than dredge spoils
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Oil-Filled Equipment – what is it?
• Oil-filled operational equipment includes an
oil storage container in which the oil is
present to support the function of the
apparatus or device.
• Examples of Oil-Filled Operational Equipment
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Hydraulic Systems
Gear Boxes
Machining Coolant Systems
Heat Transfer Systems
Transformers
Circuit Breakers
Electrical Switches
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State Regulations
• May have similar or overlapping
regulations
– AST regulations
– Petroleum bulk storage facilities licensing
– State “SPCC” programs
• However, no there are no “authorized” or
equivalent state programs – you must
comply with the federal requirements
irrespective of any state program!
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Navigable waters of the US - do I
have the potential to discharge?
YES!
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The SPCC Plan
– Format and Content
– PE Certification/Management Approval
– Updates and Re-Certification
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SPCC Plan Format
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Emergency Action Plan
SPCC Plan Text
Tables and Figures
Appendices
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SPCC Plan Content
• Facility Information
• Oil Spill Contingency Plan
• Preventive Measures
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SPCC Plan Tables and Figures
• Table
– oil storage devices and oil-filled equipment
– secondary containment
– spill pathways
• Site Locus Plan
• Site Diagram
– drainage/spill pathways
– oil storage devices and oil-filled equipment
– piping
– emergency/communications equipment
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SPCC Plan Appendices
• Inspection forms
• Secondary containment calculations
• Tank integrity testing schedule
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SPCC Plan Certification
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Your SPCC Plan must be:
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Approved by company management (corporate officer or
designated representative such as EHS manager)
Certified by a licensed Professional Engineer (PE)*
Some states require that the PE be licensed in the state
where the facility is located (NOT a federal requirement)
Must identify an Emergency Coordinator (EC)
Grant authority for the EC to commit company
resources for spill response
*Unless your facility is a Tier I or II “Qualified Facility”
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SPCC Plan
• Annual review recommended
• Five-year comprehensive review and
recertification required
• Administrative updates (e.g., new phone
numbers) do not require recertification
• Plan review and recertification for technical
amendments
– New tanks or storage systems
– New/different product storage
– Changes in facility design/operation
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SPCC Plan Implementation
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Inspections
Secondary Containment
Stormwater Management
Oil Transfers and Active Measures
Tank Integrity Testing
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INSPECTIONS
• Inspections are conducted to identify
malfunctions, deterioration, operator error, and
deficiencies which may cause or lead to
spills/releases of oil
• SPCC requires periodic inspections
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INSPECTIONS (Continued)
• Oil-filled equipment, containers, and storage area are
visually inspected on a weekly basis for the following:
– All equipment will be examined (where applicable) for leaks
from seams, rivets and bolts and gaskets and for signs of
deterioration (e.g., discoloration, corrosion, cracks) of the
vessel, aboveground foundation and structure supports;
– All associated piping will be checked for dripping, loose joints,
damage to supports, and pipe deflection;
– All connections will be checked for leakage, drainage,
tightness, and appropriate capping;
– All pumps will be checked for evidence of leakage, proper
operation, and damage;
– All storage areas and containment systems will be inspected
for integrity and the accumulation of stored product. If oil is
observed in the containment system, the source of the oil will
be determined; and
– The security of the containers/areas/equipment will be
checked (i.e., valves and equipment locked and secured).
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INSPECTIONS
• Three potential outcomes:
1. All OK
2. Non-emergency problem detected –
corrective action/maintenance required
3. Actual spill or leak identified
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CONTAINMENT SYSTEMS
• Prevent migration of spill/release from immediate
area
• SPCC containment requirements
– Oil storage tanks have 100 percent containment (plus
adequate freeboard for precipitation for outdoor tanks)
– Drum/container storage areas have containment for 10
percent of total storage capacity
– Oil-filled equipment – secondary containment where
practicable
– For oil-filled equipment without containment, alternative
measures in place including training, spill response
equipment, inspections
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Stormwater
• Stormwater Drainage Procedure
– Dike drains must be closed and locked!
– Visually inspect for oil sheen/evidence of
contamination
– Open valves and allow stormwater to drain
– Log each stormwater drainage event
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Oil Transfers
• Spills happen when/how?
– DURING TRANSFER OPERATIONS!
– Deliveries, re-fueling, equipment
maintenance etc
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Secondary Containment for Transfer Areas
• SPCC requirements
– Secondary containment needs to be sized only to address
the typical failure mode and quantity for the item
– Passive or active measures can be utilized
– Specific provisions such as drip pans, sumps, and collection
systems are recommended
• Overall result:
– Facilities will have discretion in meeting general secondary
containment requirements, consistent with good engineering
practices
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Secondary Containment – Example –
Active (Temporary) Measure
• Storm drain liner and dam
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Transfer Location Checklist
• Identify all transfer points?
• HIGH-RISK LOCATIONS?
• Included in SPCC plan?
– Table and site diagram if fixed location
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Most probable spill?
Spill pathways?
Containment?
Active measures?
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Integrity Inspections for
Aboveground Storage Tanks
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Category 1 Tanks
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Category 1 tanks as defined by Steel Tank Institute (STI) are:
– Aboveground tanks
– < 5,000-gallon capacity
– Steel construction
– Not in direct contact with the ground surface
• On legs or cradles
• Tank bottom not in contact with soil or concrete/asphalt base
– Has a continuous release detection method (CRDM)
• What does this mean?
– Passive system, not requiring sensors or power to operate, that
allows inspector to visually detect a release. Examples include
secondary containment including vaults, dikes and double-walled
tanks.
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Steel Tank Institute (STI) SP001
Inspection Standard
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Category 1 tanks < 5,000-gallon capacity are recommended only
for periodic visual inspection
Inspections are to be performed in accordance with STI SP001
standard:
– Monthly inspections
– Annual inspections (more detailed)
– Owner’s inspector must meet the requirements of the standard
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STI SP001 provides detailed program including:
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Inspector qualifications (paragraph 4.1)
Inspection instructions (Section 6)
Monthly and annual inspection checklists (Appendix C)
Recordkeeping
Immediate action items and corrective action recommendations
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12 Steps to Compliance – SPCC Facility
Inspection and AST Integrity
Inspection/Testing Program
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STEP 1: Establish routine periodic (weekly or monthly) visual inspection program
STEP 2: Get a copy of STI SP001 standard for your facility
STEP 3: Ensure that your SPCC monthly checklist includes all required items
STEP 4: Provide hands-on training to facility personnel involved in inspections
STEP 5: Do your monthly inspections!
STEP 6: Maintain signed inspection records on file for at least three years
STEP 7: Perform annual comprehensive tank condition inspection using STI
checklist and protocol
STEP 8: Utilize facility manager/engineer or someone with technical training to
perform the annual inspection if available
STEP 9: Maintain signed annual inspection forms on file for at least three years
STEP 10: Be proactive about tank housekeeping and preventive maintenance
STEP 11: Keep good records of repairs and preventive maintenance
STEP 12: Relax and feel good that you are in compliance!!!
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Inspections and Testing/
SPCC Recordkeeping
• Keep written procedures and records of the inspections
and tests for at least 3 years.
• Inspection forms and training records must be signed by
the inspector or supervisor.
• Records and forms include:
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Daily/weekly/monthly visual inspections
Containment area drainage logs/stormwater discharge forms
Tank construction records
Tank testing records
Tank repair/alteration history
Training records
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Personnel Training
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Oil-handling personnel must be adequately trained in:
– The operation and maintenance of equipment to prevent
discharges;
– Discharge procedure protocols;
– Applicable pollution control laws, rules, and regulations;
– General facility operations;
– Contents of the facility SPCC Plan; and
– Spill briefings (lessons learned, malfunctions at your and other
facilities, and precautionary measures).
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Initial and annual refresher training for all personnel involved in oilhandling
Discharge prevention meetings held at least once per year
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Personnel Training –
Practical Considerations
• Training should include practical, facility-specific
information on what do in case of a spill:
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Who is the EC and who are the alternates
Where is the spill response equipment located
Who is your spill response contractor
Who needs to be notified, and who makes the notifications
AND MOST IMPORTANTLY, SAFETY CONSIDERATIONS:
• what size spill is too big to address with training levels of
personnel and available materials/equipment
• evacuation – how to decide, how to evacuate, where to muster
• when to call 911 and get out!
• If you have not established procedures and provided
training for facility personnel, the odds of a successful spill
response are very poor!
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Personnel Training –
Practical Considerations
• If facility personnel are expected to provide anything
beyond initial response (identification, closing
valves/shutting off controls, and evacuating the area), they
need additional spill response training:
– Industry standard is OSHA 24-hour emergency response
training
– Personnel expected to operate in protective clothing such as
SCBAs may need additional training (e.g., OSHA 40-hour
HAZWOPER)
– 8-hour annual refresher required for these qualifications
– Facilities subject to FRP requirements have additional
requirements for annual spill response drills and exercises
– Personnel expected to be involved in longer-term responses
should have Incident Command System (ICS) training
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SPCC Resources
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EPA SPCC Website
– http://www.epa.gov/emergencies/content/spcc/
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EPA Guidance for Regional Inspectors
– http://www.epa.gov/emergencies/content/spcc/spcc_guidance.htm
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– This has not been updated to reflect the latest amendments
but is still a great resource
OR
– Tim Kipp, CHMM
– GZA GeoEnvironmental, Inc.
– 4 Free St
– Portland, ME 04101
– (207) 358-5121
– timothy.kipp@gza.com
– www.gza.com
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SPCC Resources
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EPA SPCC Website
– http://www.epa.gov/emergencies/content/spcc/
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EPA Guidance for Regional Inspectors
– http://www.epa.gov/emergencies/content/spcc/spcc_guidance.htm
– This has not been updated to reflect the latest amendments
but is still a great resource
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Steel Tank Institute
– http://www.steeltank.com/
– STI Standard SP001 for inspection of shop-fabricated tanks
– Includes inspection requirements/forms for periodic visual
inspection of Category 1 tanks by owner’s representative
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