SPCC plan template › SPCC plan requirements
SPCC plan requirements: the checklist
An SPCC plan must be written, approved by a manager who can commit the money, and certified (by a PE, or by the owner at a qualified facility). It must list your containers (and, except in a Tier I plan, show them on a facility diagram), describe how you prevent, contain and respond to spills, your containment, inspections, training and security, and who to call. The checklist below follows 40 CFR 112.7 and, for most facilities, 112.8.
The general requirements (112.7)
| Element | Rule | What to write |
|---|---|---|
| Management approval | 112.7 intro | Signature of someone with authority to commit the resources to implement the plan |
| Plans not yet in place | 112.7 intro | Equipment or procedures not yet operating, in separate paragraphs, with installation and start-up details |
| Conformance | 112.7(a)(1) | How the facility meets each applicable requirement |
| Deviations | 112.7(a)(2) | For any rule you meet another way: the reason and how the alternative gives equivalent protection (not allowed for containment rules, and PE-only) |
| Layout and facility diagram | 112.7(a)(3) | Location and contents of each fixed container, the area for portable containers, transfer stations and connecting pipes; exempt buried tanks marked "exempt" |
| Container list | 112.7(a)(3)(i) | Oil type and capacity of each fixed container; for portable containers, the number, oils and capacities, or an estimate |
| Prevention | 112.7(a)(3)(ii) | Routine handling: loading, unloading and transfers |
| Drainage controls | 112.7(a)(3)(iii) | Containment around containers and equipment, and how a discharge is controlled |
| Countermeasures | 112.7(a)(3)(iv) | How spills are discovered, responded to and cleaned up, by your crew and by contractors |
| Disposal | 112.7(a)(3)(v) | How recovered oil and sorbents are disposed of legally |
| Contact list | 112.7(a)(3)(vi) | Response coordinator, National Response Center, cleanup contractors, federal, state and local agencies |
| Reporting information | 112.7(a)(4) | What a caller must give: address, time, oil, quantity, source, cause, media affected, injuries, actions, evacuation, who else was called |
| Emergency use | 112.7(a)(5) | Spill procedures organized so they can be used in an emergency |
| Failure prediction | 112.7(b) | For each likely equipment failure: direction, rate of flow and total quantity of oil |
| General containment | 112.7(c) | Dikes, berms, curbing, drip pans, sumps, sorbents or similar wherever oil could escape, sized for the typical failure |
| Impracticability | 112.7(d) | Only with a PE: why containment isn't practicable, plus integrity testing and a contingency plan |
| Inspections and records | 112.7(e) | Written inspection procedures; signed records kept with the plan for three years |
| Training | 112.7(f) | Who is trained, the accountable person, annual briefings |
| Security | 112.7(g) | Access control, locked valves and pump starters, capped connections, lighting |
| Loading racks | 112.7(h) | Only if you have a tank car or tank truck rack: containment for the largest compartment, interlocks or chocks, outlet checks |
| Brittle fracture | 112.7(i) | Field-erected tanks only: evaluation after repair, alteration or failure |
| State rules | 112.7(j) | Conformance with stricter state rules |
| Oil-filled equipment | 112.7(k) | Optional: inspections plus a contingency plan instead of containment, if that equipment has a clean spill record |
The specific requirements for most facilities (112.8)
A yard, shop, farm, warehouse or plant that isn't an oil production site adds these:
- Diked-area drainage (b)(1)–(2): drains held by manual open-and-closed valves, never flapper valves; pumps started by hand after checking the water for oil.
- Undiked areas (b)(3)–(4): drainage that flows to a pond, lagoon or catchment basin that holds oil, or a diversion system at the last ditch.
- Compatible containers (c)(1): tank material suits the oil, pressure and temperature.
- Sized containment (c)(2): the largest single container plus freeboard for rain; see secondary containment requirements.
- Rainwater release (c)(3): bypass valve sealed shut, water inspected, valve reopened and resealed under supervision, records kept.
- Buried and partly buried tanks (c)(4)–(5): corrosion protection and, for buried metal tanks, regular leak testing.
- Integrity testing (c)(6): each aboveground container on a schedule set by an industry standard, plus frequent visual checks.
- Overfill devices (c)(8): at least one of a high-level alarm, a pump cutoff, direct communication with the pump station, or a fast-reading gauge watched during filling; tested regularly.
- Leaks (c)(10): visible leaks corrected promptly and oil in diked areas removed promptly.
- Portable containers (c)(11): positioned to prevent a discharge, with sized containment.
- Piping (d): buried piping installed or replaced since August 16, 2002 wrapped, coated and cathodically protected (or meeting the underground tank piping rules); idle connections capped and marked; supports designed for wear; aboveground valves and piping inspected regularly; vehicles warned away from piping.
What a Tier I plan may simplify
A Tier I qualified facility meets a shorter list set out in 112.6(a)(3). It skips the facility diagram, the conformance and deviation paragraphs, the prevention, drainage-control and disposal descriptions of 112.7(a)(3)(ii), (iii) and (v), loading racks, brittle fracture and the state-rules paragraph, and from 112.8 the undiked-area drainage rules and the piping rules other than regular inspection. Three rules are simplified: it predicts direction and total quantity of a failure without the rate of flow, sizes containment for every bulk container including portable ones, and may describe a written overfill procedure instead of picking an alarm from (c)(8). It may not include deviations or impracticability determinations at all; EPA's template already follows this list. The Tier I vs Tier II guide sets out the rest.
Five kinds of information every plan holds
A question people often search is which five types of information are in an SPCC plan. The rule doesn't number them, but a plan always holds: (1) a description of the facility and its oil containers, with a diagram unless it's a Tier I plan; (2) how spills are prevented in day-to-day handling; (3) how a spill is contained and kept from water; (4) how a spill is found, reported and cleaned up, with the contact list; and (5) the inspection, training and record-keeping program that keeps the plan true.
One more form: the substantial harm certification
Larger sites may also need a Facility Response Plan: one that transfers oil over water to or from vessels and has 42,000 gallons or more, or one with 1 million gallons or more that meets one of four other conditions (112.20(f)). A facility that doesn't meet those criteria completes the one-page "Certification of the Applicability of the Substantial Harm Criteria" in Attachment C-II of Appendix C to 40 CFR 112 and keeps it at the facility (112.20(e)). For a small yard, shop or farm the answers are all no, but the signed form is still expected.
Keep it current
Amend the plan within six months of any change that affects spill potential, and review it at least every five years (review and amendments). Keep a complete copy at the facility if it's attended at least four hours a day.
ePlan's SPCC draft follows these sections for a qualified facility and marks each item it can't confirm from your answers or public maps; you check it against this list before you sign.