Environmental Risk Management | Spill Prevention Plans

Spill Prevention Control & Countermeasure Plan

The Environmental Protection Agency (EPA) requires commercial facilities that maintain petroleum storage systems to maintain a Spill Prevention Control and Countermeasure (SPCC) Plan. A SPCC Plan is designed to protect public health, public welfare, and the environment from potential harmful effects of oil/petroleum discharges to navigable waters and adjoining shorelines. The Plan must be reviewed at least once every five years from the date of the initial review to include more effective prevention and control technology and any modification and/or amendments.

Who is regulated by the SPCC regulations?

Stated directly from the Environmental Protection Agency, a facility is subject to the SPCC rule, only if it meets three criteria:

  1. It must be non-transportation-related;
  2. It must have an aggregate above ground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons; and
  3. There must be a reasonable expectation of a discharge into or upon navigable waters of the United States or adjoining shorelines.

SPCC Plans are the responsibility of the facility owner/operator. An engineer or consultant can prepare it, but for anything other than Tier I or Tier II, a registered Professional Engineer (PE) must certify it. The Professional Engineer, having examined the facility, confirms that:

  1. (s)he is familiar with the requirements of Part 112;
  2. the engineer or their agent has visited and examined the facility;
  3. the Plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards, and with the requirements of Part 112;
  4. procedures for required inspections and testing have been established; and
  5. the Plan is adequate for the facility.

You can see more detail from the Environmental Protection Agency on those rules here. See the image below from the EPA to get a visual on how this works.


What is considered as oil storage capacity?

Many clients ask what is considered as oil storage capacity? According to the EPA, oil storage includes all containers storing oil at a facility that are equal to or greater than 55 gallons. The capacity of the containers must be considered and not the actual amount of product stored in the container. Oil storage containers include the following:

  • Tanks
  • Containers
  • Drums
  • Transformers
  • Oil-filled electrical equipment
  • Mobile or portable totes

What is an oil?

This is extremely imperative for the subject organization to know the definition of an oil. Under the SPCC regulations, oil is defined as: “Oil of any kind or in any form including, but not limited to, petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes other than dredged spoil and oily mixtures.” This also includes:

  • Non-petroleum oils
  • Synthetic oils
  • Animal fats
  • Oils and greases
  • Vegetable oils

SPCC Regulations & Plans At ERMI

A SPCC Plan must be well thought out and prepared in accordance with good engineering practices, which ERMI respectfully maintains. ERMI services property assessment needs from Phase I Environmental Site Assessments through remediation of contaminated properties. ERMI also characterizes mixed contamination plumes; fingerprints unknown petroleum compounds, and performs forensic investigations into the source and release date of contamination.

Corporate headquarters for Environmental Risk Management is located in Fort Myers, Florida. ERMI serves all of Florida with our complete service offering. Environmental Risk Management has been in the environmental consulting business in Florida since 1999. We have staff positioned throughout the state of Florida and offer forensic services throughout the nation. ERMI will help minimize your risk by offering valuable services to meet your needs.

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