4 Things You Never Knew About SPCC Plans

What happens when oil spills at your facility? Chances are if you’ve never had a major spill, you may not have a plan for how to address it when it happens.

But what you may not know is that the EPA requires any facility with the capacity to store more than 1,320 gallons of oil to have a Spill Prevention, Control, and Countermeasure Plan, or SPCC Plan. These plans can be fairly complex, but ultimately, they’re just way to document the steps you’ll take to keep oil from seeping into U.S. waterways.

Our team has put together countless SPCC Plans for facilities all across the U.S., including Lockheed Martin, ConocoPhillips, and Valvoline, and in the process, we’ve found there’s a lot about SPCC Plans that facility managers don’t know. Here are the top 5.

1. “Oil” means more than just petroleum

If when you hear “oil spill” you only think of petroleum, you’re not alone. However, the EPA includes several more types in its definition of oil, and any of them can trigger the need for a SPCC plan. These include but are not limited to:

• Animal fats and greases
• Vegetable oils (like canola or olive)
• Seed or nut oils (like sunflower, peanut, or palm)

If your facility stores more than 1,320 gallons of any of the above oil types, you need to have a SPCC Plan in place.

2. Groundwater is considered navigable

Just because you can’t sail a boat on it doesn’t mean that groundwater is safe from oil. Spills can easy reach groundwater as they soak in, and once they do, that spill can quickly spread to other bodies of water and create an environmental hazard. And though the EPA has been known to be more lenient where groundwater is concerned, your state’s regulations may be more strict.

3. Your facility likely needs a Tier II plan

Not sure what kind of SPCC plan you need? That ultimately depends on the storage capacity of your facility, but more likely than not, you need a Tier II plan. According to the EPA, 66% of the more than 650,000 regulated facilities are Tier II facilities, which means they have less than 10,000 gallons of oil and petroleum on site, but at least one tank is larger than 5,000 gallons.

Other types of plans include a Tier I plan for facilities with less than 10,000 gallons of storage space and no tank larger than 5,000 gallons, and PE Certified Full SPCC Plans for facilities with a storage capacity greater than 10,000 gallons.

4. Stationary machinery counts toward your oil storage capacity

Think your storage tanks are the only capacity you’ll need to worry about? Think again. The EPA calculates the storage space in “electrical or operating equipment” as well, including,

• Hydraulic systems
  
• Lubricating systems (e.g., those for pumps, compressors and other rotating equipment, including pumpjack lubrication systems)
  
• Gear boxes
  
• Machining coolant systems
  
• Heat transfer systems
  
• Transformers
  
• Circuit breakers
  
• Electrical switches
  
• Manufacturing equipment such as process vessels
  
• Other equipment used in the alteration, processing or refining of crude oil and other non-petroleum oils, including animal fats and vegetable oils.

It’s important to note, though, that mobile heavy machinery like forklifts, track hoes, or other construction equipment don’t need to be included in your SPCC Plan.

Leave the planning to us

Need a new SPCC Plan or an update to your existing one? Our small but experienced team has more than 50 years of combined experience in environmental consulting, and we’re happy to help you get back into compliance. Contact us to learn more about our process.