This document provides an overview of Spill Prevention, Control, and Countermeasure (SPCC) plans, which are special rules to prevent oil discharges into U.S. waters. It outlines key requirements and secrets of SPCC plans, such as what constitutes an oil, circumstances for self-certification, the powers of professional engineers, requirements for secondary containment and industry standards, and enforcement. The document emphasizes that SPCC plans must say what facilities do and facilities must do what the plans say to prevent oil spills.

1. SPCC
Secrets Andrew D. Shroads, QEP
614.887.7227 • ashroads@scainc.com
PO Box 1276
Westerville, OH 43086
While every effort has been made to ensure the accuracy of this information, SC&A is not
responsible for any errors or omissions. This information is not a substitute for professional
environmental consulting services. If legal services are required, consult with legal counsel.

2. SPCC Background
Spill Prevention, Control, and Countermeasure (SPCC) Plans
are special rules to prevent the discharge of oils into the
navigable waters of the United States.
• Regulations found in Oil Pollution Prevention Rules, Title
40 of the Code of Federal Regulations (CFR), Part 112
• Originally issued on December 11, 1973 (38 FR 34164)
• Amended and greatly expanded in 2002
◦ Specific requirements for separate categories
◦ Reduced counted container size from >660 to ≥55 gallons
◦ Updated compliance dates
◦ Allows equivalent environmental measures
• Last amended on April 18, 2011
◦ Exempted milk and milk product containers from SPCC
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3. SPCC Discharges / Spills
Reportable Discharge: contact National Response Center at
(800) 424-8802 and state water quality agency
• Any amount of oil causing a sheen on the water [§110.3]
• In Ohio: ≥25 gallons of oil [OAC 3750-25-20(A)(2)]
◦ Other states have higher or lower thresholds
• Hazardous substance above threshold quantity [§302.6]
SPCC Actionable Discharge: additional reporting and affects
site classifications in SPCC rules [§112.4(a)]
• One discharge >1,000 gallons in the past 3 years
• Two discharges >42 gallons within any 12-month period in
the past 3 years
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4. SPCC Secrets
SPCC Plans: Site-specific implementation of 40 CFR 112
Big Secret: SPCC Plans SAY what you DO; DO what they SAY
Other SPCC Secrets:
1. Regulate all oil discharges
2. Can be self-certified, in some cases
3. Give Professional Engineers (P.E.) special powers
4. Must be reviewed and evaluated every 5 years
5. Must incorporate industry standards (NFPA, API, etc.)
6. Must require secondary containment in most cases
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5. Secret #1: What is an oil?
Non-petroleum Oils: [§112.2]
◦ Animal oil, fats, or grease (e.g. cafeteria grease traps)
◦ Vegetable oil
Petroleum Oils: [§112.2]
◦ Fuel oils (e.g. diesel fuel, gasoline)
◦ Petroleum products (e.g. mineral spirits)
◦ Synthetic oils
◦ Mineral oils (e.g. coal tar)
◦ Oil refuse
◦ Oil mixed with wastes (other than dredged spoil)
Not An Oil: [§112.1]
◦ Milk
◦ Hot-mix asphalt
U.S. Coast Guard maintains a list of oils
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6. Secret #2: Self-certification
Two types of facilities that can self-certify, IF no actionable,
reportable discharges in the past three years:
• Tier I: No single aboveground container >5,000 gallons
[§112.6(a)]
• Tier II: Aggregate aboveground capacity ≤10,000 gallons
[§112.6(b)]
There is a self-certification template SPCC plan in 40 CFR,
Part 112, Appendix G. Self-certification is for simple facilities
with adequate controls and knowledge of industry standards.
Self-certification does not allow for environmental equivalence
(alternate requirements); only a P.E. can determine
environmental equivalence.
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7. Secret #3: Professional Engineer Powers
P.E. have special powers in drafting SPCC Plans:
1. Environmental Equivalence: alternative measures
equivalent to applicable requirements [§112.7(a)(2)]
2. Impracticability Determinations: secondary containment
impractical; alternative measure provided [§112.6(b)(3)(ii)]
Alternative measures must:
• Be consistent with good engineering practice; and
• Consider applicable industry standards / rules [§112.7]
If a P.E. signed your original SPCC plan, a P.E. must certify
any technical amendments to that SPCC plan.
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8. Secret #4: 5-year Review - 1
Review and evaluate SPCC Plan [112.5(b)]
• Anniversary date is from last five year review or when your
facility became subject to SPCC Plan requirements
• Amend SPCC Plan within 6 months of review to include
more effective prevention or control technologies
◦ Field-proven at time of review
◦ Significantly reduce likelihood of a discharge
• Incorporate modifications to industry standards
◦ ANSI B31 (Pipelines): Updated 2016
◦ NFPA 30 (Flammable Liquids): Updated 2015
◦ NFPA 55 (Compressed Gases): Updated 2016
◦ NFPA 67 (Pipelines): Updated 2016
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9. Secret #4: 5-year Review - 2
5-year review best time to update your SPCC Plan:
• Is the emergency contact information correct?
• Are the people referenced in the SPCC Plan still in those
positions?
• Are inspections being conducted at correct frequency?
• Are sufficient records being maintained?
• Consider independent 3rd party audit
SPCC: HOW the facility complies with 40 CFR 112
• WHO is responsible
• WHAT is necessary
• WHEN is it required
• WHERE is it located
• WHY are you doing it
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10. Secret #5: Industry Standards
Industry Standards: set of criteria relating to the function and
operation of a specific industry [§112.3(d)(1)(iii)]
• Aboveground tanks:
◦ API: Spec 12P, RP 12RI, 650, 651, and 653
◦ Others: STI SP001, NFPA 30, and UL142
• Underground tanks:
◦ API: RP 1615, RP 1631, and RP 1632
• Pipelines:
◦ API 570 and RP 1632, ASME B31.3, B31.4, and B31.5,
NFPA 30, and NACE RP 0285 and RP 0169,
• Overfill Protection:
◦ NFPA 30, API 2350
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11. Secret #6: Secondary Containment - 1
Secondary containment is required for all bulk storage
containers, pipelines, and transfer and oil-filled equipment
• Oil-filled operational equipment does not require secondary
containment IF the facility has not had a actionable,
reportable discharge AND has a separate inspection and
monitoring program [§112.7(k)(1)]
• P.E. can establish alternative measures where secondary
containment for bulk storage containers is impracticable
[§112.6(b)(3)(ii)]
◦ Periodic integrity testing
◦ Requires oil spill contingency plan
◦ Written commitment of manpower, equipment, and
materials for control and removal of any oil discharge
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12. Secret #6: Secondary Containment - 2
Remember: ACTIVE or PASSIVE secondary containment
Passive Secondary Containment: does not rely on operator
or plant personnel to work [§112.7(c)(1)]
• Containment pallets
• Berms / walls
• Separate containers
• Drip trays
Active Secondary Containment: relies upon operators to
work; Cannot use at unattended facilities! [§112.7(c)(1)]
• Drain covers
• Sumps or collection systems
• Spill kit or sorbent materials (socks, booms, mats, etc.)
• Prepared spill response team
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13. SPCC Enforcement
• Ohio EPA does not regulate SPCC Plans, but Ohio Senate
Bill 367 (1988) incorporated by reference 40 CFR 112
• Ohio State Emergency Response Commission and Ohio EPA
both require notifications of reportable spills / discharges,
including oil
◦ Both agencies and their delegates (County Emergency
Planning Commissions and Fire Departments) can request
copies of an SPCC Plan during / after discharge
• U.S. EPA Region 5 inspectors conducting audits will request
copies of SPCC Plans during onsite investigation
After a spill or discharge, do you have copies of the
records and reports required by your SPCC Plan?
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14. AdditionalAssistance
Helpful Websites:
SPCC Guidance for Regional Inspectors
• https://www.epa.gov/oil-spills-prevention-and-
preparedness-regulations/spcc-guidance-regional-
inspectors
Specifically, Appendix H has letters and guidance from EPA
regarding specific concerns
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