1. 1
SPCC Overview

2. 2
Outline
1. Background
2. SPCC Applicability
3. Written SPCC Plan Requirements
4. Implementation of SPCC Requirements

3. 3
USEPA Office of Emergency
Management: Oil Pollution Prevention
 Prevention
– SPCC
 Preparedness
– Facility Response Plans (FRP)
– Area Contingency Plans
 Response
– National Contingency Plan
– Local, State, Federal (EPA & USCG),
Responsible Party

4. 4
USEPA - Region 4 Emergency
Response Program
 Cadre of 30 Federal On-Scene Coordinators (OSCs)
– Based in Atlanta, GA. Outpost locations in Mobile, AL,
Tallahassee, FL, Louisville, KY, Raleigh, NC, Jackson, TN
 24/7 On-Call Status
 Respond to releases of hazardous substances and oil
spills;
 All environmental hazards response (air, water, land,);
 Federal disaster and WMD/CT response capability;
 Planning and Preparedness (Drills)
 Oil Pollution Prevention (SPCC and FRP
Inspections)

5. 5
Oil Pollution Prevention Regulations –
SPCC Rule – 40 CFR 112
 Spill, Prevention, Control, and
Countermeasure (SPCC) regulation (40 CFR 112)
requires the preparation and implementation of site-
specific plans to prevent oil discharges that could
affect navigable waters
 Authority: Clean Water Act (CWA) § 311(j)(1)(C)
and 501 and codified under 40 CFR Part 112
 EPA’s Office of Emergency Management administers the Rule

6. 6
Oil Pollution Prevention Regulations –
FRP Rule - 40 CFR 112.20
 Facility Response Plan (FRP) regulations
require certain facilities to prepare and submit to
EPA plans to respond to discharges of various
sizes
– Only applies to a subset of SPCC regulated facilities
 Basis: 1990 OPA amendments to CWA
 Authority: CWA §§ 311(j)(5) and 501, and
codified under 40 CFR §§112.20-112.21

7. 7
Purpose SPCC - (40 CFR Part 112)
 To prevent oil discharges from reaching
the navigable waters of the U.S. or
adjoining shorelines;
 To ensure effective and proactive
measures are used in response to an oil
spill;

8. 8
Purpose of SPCC?

9. 9

12. History of Oil Pollution Prevention Regulations
1972 Federal Water Pollution Control Act Amendments
1974 Original SPCC Rule Published
1988 Ashland Oil Spill – SPCC Task Force Formed
1989 Exxon Valdez Spill in Alaska
1991/93 Proposed SPCC Rule Revisions
1994 Final Facility Response Plan (FRP) Rule published
2001 Draft Final SPCC Rule Revisions
2002 Final “Revised” SPCC Rule published 7/17/02
2004 SPCC litigation settlement
2006 SPCC Rule Amendments published 12/26/06
2008 SPCC Rule Amendments published 12/5/08
2009 12/5/08 SPCC Rule amendments delayed
2009 SPCC Rule Amendments published 11/5/09
2010 Compliance Date Extension issued on 10/7/10 (except for FRPs)
2011 Compliance Date Extension for FARMs published on 10/18/11

13. 13
Applicability of SPCC

14. General SPCC Rule Applicability
The SPCC rule applies to a facility that meets the
following criteria:
Drills, produces, gathers, stores, processes, refines, transfers,
distributes, uses, or consumes
oil and oil products; and
Is non-transportation-related; and
Due to location, could reasonably be expected to discharge oil in
quantities that may be harmful into or upon the navigable waters
of the U.S. or adjoining shorelines; and
Meets capacity thresholds
• Aboveground storage > 1,320 gallons; or
• Completely buried storage > 42,000 gallons*
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(*Note: many USTs are exempt from the SPCC Rule)

15. 15
Definition ofDefinition of “Facility”“Facility” – (– (§ 112.2)112.2)
Facility means any mobile or fixed, onshore or offshore building, property,
parcel, lease, 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
oil waste treatment, or in which oil is used, as described in Appendix A to this
part. 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 types of activity at the site. Contiguous or
non-contiguous buildings, properties, parcels, leases, structures,
installations, pipes, or pipelines under the ownership or operation of the
same person may be considered separate facilities. Only this definition
governs whether a facility is subject to this part.
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16. 16
Oil (§ 112.2)
 Includes oil of any kind or in any form such as:
– Petroleum and fuel oils
– Mineral oils
– Sludge
– Synthetic oils
– Oil mixed with wastes other than dredged spoil
– Animal fats, oils, and greases
– Vegetable oils
Note: E85, and Bio-Diesel are oils for SPCC purposes.
Denatured ethanol (if denaturant is an oil) is also.
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17. Natural Gas
 Natural gas (including liquid natural gas and liquid petroleum gas) is
not considered an oil
Hazardous Substances and Hazardous
Waste
 Hazardous substances that are oils, or mixed with oils, are subject to
SPCC rule requirements
– Containers storing these substances may also be covered by RCRA and
CERCLA
 Tanks containing RCRA hazardous wastes are not subject to the UST
rules, and therefore are not exempt under §112.1(d)(2)(i) or (4) if they
contain oil
 Hazardous substances that are not oils nor mixed with oils are not
subject to SPCC rule requirements
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18. Storage Capacity Calculation
Included in storage capacity Excluded from storage capacity
*Containers (i.e. bulk storage
containers, oil-filled equipment,
mobile/portable containers) with a
capacity of 55 gallons or greater.
*Completely buried tanks and
associated underground piping, &
ancillary equipment, subject to all
technical requirements of 40 CFR part
280 or 281
*Containers used exclusively for
wastewater treatment
*Motive power containers
*Hot mix asphalt containers
*Pesticide application equipment and
containers
*Heating oil containers at single family
residences
*USTs deferred under 40 CFR 280 and
vaulted tanks at nuclear power facilities
*Capacity of containers that are
permanently closed.
Meets capacity thresholds55

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Navigable waters
Navigable Waterways could include:
 Traditional navigable waters
– Rivers
– Lakes
 Tributaries of navigable waters
– Creeks & Streams
– Wetlands
Also consider conduits to navigable waters
 Storm drains, storm sewers
 Ditches
 Wetlands
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21. 21

22. 22

23. Service Station
Dispenser Island
ASTs
Street
Restaurant
Overland Path of
Oil Spill
Storm Drain – connects
To Storm Drain at
Street
Truck Transfer
Area
Unnamed Tributary (Fish Kill)

24. Current Compliance Dates
A facility starting operation… Would…
On or before 8/16/02 Maintain existing Plan.
Amend and implement Plan no
later than 11/10/2011 *
After 8/16/02
through 11/10/2011*
Prepare and implement Plan no
later than 11/10/2011*.
After 11/10/2011*
(excluding production facilities)
Prepare and implement Plan
before beginning operations.
After 11/10/2011*
(production facilities)
Prepare and implement Plan
within 6-months after beginning
operations
*Note: For FRP facilities and for off-shore drilling, production, & workover SPCC
facilities, the compliance date was 11/10/2010.
Extends the dates by which a facility must amend and
implement its SPCC Plan in accordance with revisions to the
rule promulgated since 2002

25. Farm Compliance Dates
A farm starting operation… Would…
On or before 8/16/02 Maintain existing Plan.
Amend and implement Plan no
later than 5/10/2013
After 8/16/02
Through 5/10/2013
Prepare and implement Plan no
later than 5/10/2013
After 5/10/2013 Prepare and implement Plan
before beginning operations.
Extends the dates by which a FARM must amend and
implement its SPCC Plan in accordance with revisions to the
rule promulgated since 2002

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Requirements for Preparation
of SPCC Plans

27. §112.1 General applicability of the rule
§112.2 Definitions of terms used in the rule
§112.3 Requirement to prepare an SPCC Plan
§112.4 Amendment of SPCC Plan by RA
§112.5 Amendment of SPCC Plan by owner or operator
§112.6 Qualified Facilities
§112.7 General requirements for all facilities
§112.8 Specific requirements for onshore facilities (excluding
production facilities)
§112.9 Specific requirements for onshore production facilities
§112.10 Specific requirements for onshore oil drilling and
workover facilities
§112.11 Specific requirements for offshore oil drilling, production,
or workover facilities
§112.20 Facility Response Plans
§112.21 Facility Response training and drills/ exercises
40 CFR 112 Structure

28. Overview of information required to
be in your written SPCC Plan
 PE certification of Plan (112.3(d)
– May self-certify Plan if store 10,000 gallons or less (112.6)
 Management review of Plan (112.5(b)
 Include amendments to Plan (112.5)
 Management approval of Plan (112.7)
 List all containers including oil type and volume (112.7(a)(3)
 Site diagram (112.7(a)(3)
 Analysis of spill volumes, rates, pathways/directions (112.7(b)
 Discuss containment methods for: tanker truck
loading/unloading areas, piping, & oil filled equipment (112.7(c)
– If utilized, discuss monitoring method for oil filled op equip (112.7(k)
 Discuss impracticability determinations (if any) (112.7(d)

29. Overview of information required to
be in your written SPCC Plan cont’d
 Discuss inspection methods and procedures (112.7(e),112.8(c)(6)/(d)4)
 Discuss training (112.7(f)
 Discuss security (112.7(g)
 Discuss truck/railcar loading/unloading rack areas (112.7(h)
 Discuss secondary containment systems for tanks (112.8(c)(2)
 Discuss liquid level sensors on tanks (112.8(c)(8)
 Discuss procedures for the drainage of rainwater from
containment structures (112.8(b) & 112.8(c)(3)
 Discuss piping/transfer operational requirements (112.8(d)

30. 30
Amendments to SPCC Plan (§112.5)
 SPCC Plan must be amended within 6-months of any
change in facility design or construction which
affects the facility’s potential to discharge oil.
 Technical Amendments MUST be certified by a PE
{Qualified facilities may self-certify any amendments}
 Amendments must be implemented within 6-months
of plan change

31. If the facility has… And… And the facility has… Then:
10,000 U.S.
gallons or less
aggregate
aboveground oil
storage capacity;
Within any twelve-month
period, three years prior to
the Plan certification date,
or since becoming subject
to the SPCC rule if in
operation for less than
three years, there has
been:
(1) No single discharge of
oil to navigable waters or
adjoining shorelines
exceeding 1,000 U.S.
gallons; and
(2) No two discharges of oil
to navigable waters or
adjoining shorelines each
exceeding 42 U.S. gallons
in any 12 -month period
No individual
aboveground oil
containers greater
than 5,000 U.S.
gallons;
Tier I: Complete
and self-certify Plan
template (Appendix
G to 40 CFR part
112) in lieu of a full
PE-certified Plan.
Any individual
aboveground oil
container greater
than 5,000 U.S.
gallons;
Tier II: Prepare self-
certified Plan in
accordance with all
applicable
requirements of
§112.7 and subparts
B and C of the rule,
in lieu of a PE-
certified Plan.
Qualified Facilities – (§ 112.6) (optional)

32. SPCC Plans
 No requirement to submit SPCC Plans to EPA
 EPA does not formally “approve” or
disapprove SPCC Plans
 Plan is required upon inspection during regular
workday

33. 33
Last Word on your Written SPCC Plan
 Include discussions on each section and subsection
of the regulation in your Plan.
 Include site specific details!
– Regurgitating the regulation is not adequate

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Implementation of SPCC
Requirements

35. Implementation Requirements
 Amend SPCC Plan as needed – 112.5(a & c)
 Review SPCC Plan at least once every 5 years – 112.5(b)
 Secondary containment for loading/unloading areas – 112.7(c)
 Secondary containment for piping – 112.7(c)
 Secondary containment for oil filled operational equipment – 112.7(c)
– Monitoring program option for such equipment – 112.7(k)
 Maintain records of inspections and tests for 3-years – 112.7(e)
 Train oil-handling personnel on SPCC -- 112.7(f)
 Conduct spill prevention briefings annually – 112.7(f)
 Secure facility – 112.7(g)
 Secondary containment for truck/railcar loading racks – 112.7(h)
 Secondary containment for bulk storage containers – 112.8(c)(2)
– Containment for bulk storage containers must be sufficiently impervious

36. Implementation Requirements
 Control dike drainage; keep dike valves closed; inspect
rainwater before drainage event; keep records of drain
events - 112.8(c)(3)
 Test or inspect bulk storage containers – 112.8(c)(6)
 Provide liquid level sensors, alarms, gauges, devices to
prevent tank overflows – 112.8(c)(8)
 Correct leaks/drips from tanks, piping, valves; cleanup
accumulations of oil in diked areas – 112.8(c)(10)
 Protect buried piping; provide proper pipe supports;
Inspect piping and valves; mechanisms to protect
aboveground piping from vehicles – 112.8(d)

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Secondary Containment Requirements-
(Two types of containment)
 General Provision – (§ 112.7(c): addresses the potential for
oil discharges from any area within a regulated facility
– In determining the method, design, and capacity for secondary
containment, you need only to address the typical failure mode,
and the most likely quantity of oil that would be discharged
– Containment may be either active or passive in design
 Specific Provisions – (§ 112.8(c)(2), § 112.8(c)(11), § 112.7(h)):
addresses the potential of oil discharges from specific
parts of a facility where oil is stored or handled
– Containment design, sizing, and freeboard requirements are
specified by the SPCC rule to address a major container failure

38. 38
Example Methods of Secondary
Containment
 These are examples only.
– Dikes, berms, or
retaining walls
– Curbing
– Culverting, gutters,
or other drainage
systems
– Weirs
– Booms
– Barriers
– Spill diversion ponds
and retention ponds
– Sorbent materials
– Drip pans
– Sumps and collection
systems

39. 39
General Secondary Containment
Requirement (§ 112.7(c))
 Requires secondary containment for any area within a
facility where a discharge may occur:
– such areas can include:
Oil filled equipment (operating, manufacturing)
Truck and railcar Loading/Unloading areas
(non-rack transfer areas)
Piping
 Intended to address the most likely discharge in these
areas
 Allows for active and passive containment measures

40. Active Containment Measures
 Active containment measures require deployment or
other specific action by the owner or operator
 May be appropriate for certain discharges if it:
– Can contain the volume and rate of oil
– Is deployed in a timely manner
– Is properly constructed
 Can be RISKY !!!!!
 ARE NOT ALLOWED FOR BULK STORAGE
TANKS

41. 41
Specific Secondary Containment
Requirements
 Areas where certain types of containers, activities, or
equipment are located that are subject to more stringent
containment requirements
 Specific minimum size requirement for secondary
containment for the following areas:
– Bulk storage containers – § 112.8(c)(2)
– Loading/unloading racks – § 112.7(h)(1)
– Mobile or portable bulk storage containers – § 112.8(c)(11)
– Production facility bulk storage containers – § 112.9(c),
(includes tank batteries, separation, and treating vessels/equipment)

42. Type of Facility Secondary Containment Rule
Section(s)
ALL FACILITIES General containment (areas with potential for discharge:
piping, oil-filled operating and manufacturing equipment, non-
rack related transfer areas, mobile refuelers):
Loading/unloading racks:
OPTION: Oil-filled equipment:
112.7(c)
112.7(h)(1)
112.7(k)
Onshore Storage Bulk storage containers:
Mobile or portable oil containers:
112.8(c)(2)/
112.12(c)(2)
112.8(c)(11)/
112.12(c)(11)
Onshore Production Bulk storage containers, including tank batteries,
separation, and treating facility installations:
OPTION: Flow-through process vessels:
OPTION: Produced water containers:
112.9(c)(2)
112.9(c)(5)
112.9(c)(6)
Onshore Oil Drilling
and Workover
Mobile drilling or workover equipment: 112.10(c)
Offshore Oil Drilling Oil drilling, production, or workover equipment: 112.7(c)
Secondary Containment Provisions

43. If the facility… And the
equipment…
Then the owner/operator of the
facility…
…has oil-filled
operational
equipment
…meets the oil
discharge history
criteria described
below
…may implement an inspection and
monitoring program, develop an oil spill
contingency plan, and provide a written
commitment of resources to control and
remove oil discharged, for qualified
equipment in lieu of secondary
containment for the oil-filled operational
equipment
…does not need to make an
impracticability determination for each
piece of equipment
§ 112.7(k)(1)- To use this alternative, a facility’s oil-filled operational equipment must meet
requirements for its reportable discharge history. The facility’s oil-filled operational equipment
must not have had (1) a single discharge of oil to navigable waters exceeding 1,000 U.S. gallons
or (2) two discharges of oil to navigable waters each exceeding 42 U.S. gallons within any
twelve-month period, in the three years prior to the SPCC Plan certification date, or since
becoming subject to 40 CFR part 112 if operating for less than three years.
Oil-filled Operational Equipment Option – (§ 112.7(k)

44. 44
Bulk Storage Containers
 Must follow specific requirements as described
under § 112.8(c) for bulk storage containers
 Oil-filled operating or manufacturing equipment are not bulk storage
containers
Field Erected Tank Shop-Built Tank

45. 45
Secondary Containment for Bulk Storage
Containers: (§ 112.8(c)(2))
1. Provide secondary containment for entire
capacity of largest single container and
sufficient freeboard for precipitation
2. Ensure diked areas are sufficiently
impervious to contain discharged oil

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49. 49

50. 50
Sufficiently impervious?

51. 51
Sufficiently impervious?

52. 52

54. Mobile/Portable Containers – § 112.8(c)(11)
(55-gallon drums, totes, skid tanks)

55. Mobile/portable containers require secondary containment (§ 112.8(c)(11)

56. 56
Stormwater Drainage (§ 112.8(c)(3))
 Drainage of rainwater from diked areas can
bypass in-plant treatment if:
– Bypass valve is normally sealed closed!!
– Inspection of runoff rainwater ensures no sheen
– Bypass valve is opened and resealed following drainage un
responsible supervision
– Adequate records are kept of such events
 Records for NPDES permits are sufficient for recording stormwater bypass
events

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59. 59
Inspection and Testing of
Bulk Storage Containers (§ 112.8(c)(6))
 Test or inspect each aboveground bulk storage
container for integrity on a regular schedule and
whenever material repairs are made
– Determine, in accordance with industry standards (e.g.,
API, STI, UL), the appropriate qualifications of personnel
performing tests and inspections and the frequency and
type of testing and inspections, which take into account
container size, configuration, and design
 Allows integrity testing requirements that are outlined in
industry standards in lieu of integrity testing without the
need for environmental equivalence determinations
certified by a PE.

61. 61
Overfill sensing devices for Bulk
Storage Tanks – (§ 112.8(c)(8)(i to v))
 One of the following devices must be provided:
– High level alarms
– High liquid level pump cutoff devices
– Direct audible or code signal communications
– Fast response system for determining liquid levels of
tanks: digital, computers, telepulse, direct vision
gauges
 Must regularly test liquid level sensing devices

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63. 63
Correction of Discharges and Clean-up of
Oil Accumulations – (§ 112.8(c)(10)
 Promptly correct visual discharges resulting in a
loss of oil from containers, seams, gaskets,
piping, pumps, valves, etc
 Promptly remove any accumulations of oil

65. 65

66. 66

67. Loading/unloading rack means a fixed structure (such as a
platform, gangway) necessary for loading or unloading a tank
truck or tank car, which is located at a facility subject to the
requirements of this part. A loading/unloading rack includes a
loading or unloading arm, and may include any combination of
the following: piping assemblages, valves, pumps, shut-off
devices, overfill sensors, or personnel safety devices.
Definition of Loading/Unloading Rack

68.  Provide general secondary containment per § 112.7(c)
– Design containment methods to contain the most likely discharge in these areas
 Provide buried piping with coating/wrapping and cathodic protection
 Provide proper pipe supports
 Inspect aboveground piping for leaks, corrosion
 Cap or blank flange the terminal connections
 Warn vehicular traffic of aboveground piping
Piping Requirements – § 112.7(c) and § 112.8(d)

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71. 71
Loading Rack vs Loading/Unloading
Area Clarifications
 The loading/unloading rack provisions of
§ 112.7(h) only apply in instances where a rack
structure is present
 Loading/unloading areas utilizing a single hose
and connection or standpipe are not considered
“racks” --- these are loading/unloading areas (non-rack
transfer areas)
 Loading/unloading areas require a containment
method per § 112.7(c)
– Base containment method and volume on good engineering
practice

72. 72
Tank Car/Tank Truck Loading/Unloading
Rack Requirements - (§ 112.7(h))
 Tank car and tank truck loading/unloading racks
require secondary containment to handle a spill from
the single largest compartment of a tank car or
tank truck loaded or unloaded at the facility
 System to prevent vehicle departure before
disconnection
 Inspect vehicle drain outlets before departure

73. 73
Loading Rack

74. 74
LOADING RACK

75. 75
Loading/Unloading Area

76. 76
Security Requirements (§ 112.7(g))
– Performance-based
– Tailored to the facility’s specific characteristics and location
 A facility owner/operator is required to describe in
the SPCC Plan how facility will:
– Secure and control access to all oil handling, processing and
storage areas;
– Secure master flow and drain valves;
– Prevent unauthorized access to starter controls on oil pumps;
– Secure out-of-service and loading/unloading connections of oil
pipelines; and
– Address the appropriateness of security lighting to both prevent
acts of vandalism and assist in the discovery of oil discharges.

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SPCC Spill Reporting
 If your SPCC facility has a discharge
above the thresholds in §112.4, the Rule
requires the submission of additional
reporting information to EPA
 Reporting information must be submitted
within 60-days of spill

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For Additional Information
 Ted Walden EPA R4 404-562-8752
walden.ted@epa.gov
 Steve Spurlin 731-394-8996
Spurlin.Steve@epa.gov
 www.epa.gov/oilspill
 National SPCC/RCRA Hotline
1-800-424-9346

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