SPCC Plans

Overview & Applicability

As part of its Oil Pollution Prevention regulations, the federal Environmental Protection Agency (EPA) has established requirements for facility owners to prevent and control oil spills. The requirement that is the most generally applicable to higher education institutions is the requirement to have a Spill Prevention Control & Countermeasures (SPCC) plan.

An SPCC plan is a written plan that includes the measures to be taken at your institution to prevent and control oil spills caused either by human error or operational failures. Institutions that have a total aboveground oil storage capacity of more than 1,320 gallons in containers 55 gallons and larger must develop maintain an SPCC Plan.

An underground oil storage capacity of more than 42,000 gallons also triggers SPCC requirements. However, regulated underground storage tanks (USTs) are exempted from the capacity determination.

Key Definitions

Facility: any mobile or fixed, onshore or offshore building, structure, installation, equipment, pipe, or pipeline (other than a vessel or a public vessel) used in oil well drilling operations, oil production, oil refining, oil storage, oil gathering, oil processing, oil transfer, oil distribution, and waste treatment, or in which oil is used. The boundaries of a facility depend on several site-specific factors, including, but not limited to, the ownership or operation of buildings, structures, and equipment on the same site and the types of activity at the site.

Oil: oil of any kind or in any form including, but not limited to: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits, or kernels; and other oils and greases, including synthetic oils and mineral oils.

Storage capacity: the shell capacity of the container.

Requirements

The following is a summary of the SPCC plan requirements:

Assess your institution's overall oil storage capacity. Note that the term "oil" is very broadly defined (see definitions above), and capacity refers to maximum storage capacity and not operational capacity.
If the total storage capacity is more than 1,320 gallons, develop an SPCC plan that addresses three main areas:

the operating procedures your facility implements to control oil spills.
control measures installed to prevent oil from reaching navigable waters or adjoining shorelines.
countermeasures to contain, clean up, and mitigate the effects of an oil spill that has an impact on navigable waters or adjoining shorelines.

While the facility owner or operator has responsibility for preparing an SPCC plan, a Professional Engineer (PE) must certify and attest to the plan. The PE must also visit the facility to ensure that the plan meets good engineering practices, that necessary inspection and testing procedures have been implemented, and that the plan is effective.
Maintain a copy of the plan at the facility and available for EPA review and inspection during normal working hours.
Review the plan and maintain documentation of the plan review at least every 5 years.

The EPA has created a comprehensive checklist (PDF - 482KB) that may help your institution assess its compliance with the SPCC regulations.