SPCC plan template › Who needs an SPCC plan
Who needs an SPCC plan?
You need an SPCC plan if three things are all true: your facility stores, uses or handles oil and isn't transportation-related; it has more than 1,320 gallons of aboveground capacity in containers of 55 gallons or more, or more than 42,000 gallons completely buried; and a spill could reasonably reach a creek, river, lake or other water of the United States, or its shoreline. Miss one test and the federal rule doesn't apply.
Test 1: you handle oil, and not as a vehicle or pipeline
"Oil" is broad. EPA's list for farms and other facilities includes diesel, gasoline, lube oil, hydraulic oil, adjuvant and crop oil, vegetable oil and animal fat. Used oil counts too. The rule covers facilities that drill, produce, store, process, transfer, distribute, use or consume oil. Vehicles on the road, pipelines and rail fall under the Department of Transportation instead, but a fuel truck or trailer tank used only on your property is part of your facility, as EPA's farm answers say.
Test 2: more than 1,320 gallons aboveground, or more than 42,000 buried
Add up the shell capacity (what the container can hold, not what is in it today) of every aboveground container of 55 gallons or more. Over 1,320 gallons and you pass this test. Separately, completely buried tanks pass it at more than 42,000 gallons. Either one is enough.
Count these
- Fixed tanks, 55-gallon drums, 275 and 330-gallon totes, and portable tanks.
- Oil-filled operational equipment: hydraulic systems, transformers, gear boxes, lifts. EPA's template counts them toward the total.
- Tanks on trailers, fuel trucks used only on the property and transfer tanks in pickups.
- Partially buried tanks, bunkered tanks and tanks in vaults: the rule treats them as aboveground.
- Containers in standby, seasonal or temporary storage, unless they are permanently closed.
Leave these out
- Any container under 55 gallons.
- Permanently closed containers (emptied, sealed and marked as the rule defines).
- Motive power containers: a vehicle's or machine's own fuel tank. Fueling them still counts as a transfer.
- Heating oil used only at a single-family home; hot-mix asphalt; pesticide application equipment and its mix containers; milk containers.
- Completely buried tanks that meet all of EPA's underground storage tank rules in 40 CFR 280 or a state program under 281 (mark them "exempt" on the diagram if you need a plan anyway).
- Equipment used only for wastewater treatment.
Test 3: a spill could reasonably reach water
This is the test people misread. The rule asks whether, because of where it is, your facility could reasonably be expected to discharge oil into navigable waters or onto adjoining shorelines in quantities that "may be harmful" (a sheen is enough). You must judge it from geography alone: distance to water, land contour, drainage, ditches, gullies and storm sewers that lead to a creek. You may not count your dikes, berms, buildings or other structures that would hold a spill back (112.1(d)(1)(i)).
EPA's own advice is to picture your containment gone, estimate how much oil a failure could release, and follow where it would flow. If the honest answer is that it would never reach water, you don't need a plan, but EPA recommends writing down why so an inspector can see your reasoning. Your state may still regulate a spill that only hits soil.
Two worked examples
A contractor's yard. One 1,000-gallon diesel tank, two 275-gallon hydraulic oil totes, twelve 55-gallon drums of motor and gear oil, and a dozen machines with their own fuel tanks.
1,000 + (2 × 275) + (12 × 55) = 1,000 + 550 + 660 = 2,210 gallons Machines' own fuel tanks: motive power, not counted
2,210 gallons is over 1,320. The yard drains across gravel to a roadside ditch that feeds a creek 400 feet away, so all three tests are met: it needs a plan. With 10,000 gallons or less, no container over 5,000 and no reportable spills, it is a Tier I qualified facility and the owner may sign EPA's template.
An auto repair shop. One 500-gallon used-oil tank, twelve 55-gallon drums of new oil and fluids, and 5-gallon pails of coolant.
500 + (12 × 55) = 500 + 660 = 1,160 gallons 5-gallon pails: under 55 gallons, not counted
1,160 gallons is under 1,320, so the shop doesn't need a federal SPCC plan today. Add four more drums (220 gallons) and it reaches 1,380 gallons and does. If its shop drains lead to a storm sewer, it should plan for that before the next delivery.
When the plan must exist
A facility that starts operating now, and could reasonably discharge to water, must prepare and implement its plan before it begins operations (112.3(a)). Farms have had the same rule since May 10, 2013. You don't file the plan anywhere: you keep a complete copy at the facility if someone is there at least four hours a day, otherwise at the nearest field office, and show it to an EPA inspector on request. EPA enforces the rule through its regional offices; it has no authority to hand the program to states, though many states run their own tank rules alongside it.
Who signs once you're in
Passing all three tests tells you that you need a plan; your size and spill history tell you who may certify it. At 10,000 gallons or less aboveground with no reportable spill in three years, the owner or operator may self-certify; above that, a Professional Engineer must. The Tier I vs Tier II guide walks through which plan that is, and the farm guide covers the different farm numbers set by Congress in 2014.
Once you know you need one, ePlan can draft a self-certified plan from your address and tank list (free to read, $49 to download); EPA's own template is free if you'd rather fill it in yourself.
Questions
What are the three criteria that subject a facility to the SPCC rule?
The facility is not transportation-related and handles oil; it has more than 1,320 gallons of aboveground capacity (counting containers of 55 gallons or more) or more than 42,000 gallons completely buried; and, judged by its location alone, a spill could reasonably reach navigable water or a shoreline.
Under the SPCC rule, which containers are left out of the count?
Containers under 55 gallons, permanently closed containers, motive power containers, hot-mix asphalt, heating oil used only at a single-family residence, pesticide application equipment, milk containers, and buried tanks that meet all of the federal or state underground tank rules.
Do I count the oil in the tank or the tank's size?
The tank's size: its shell capacity. A 1,000-gallon tank kept half full still counts as 1,000 gallons.