SPCC / EPA Regulations

Understanding SPCC secondary containment requirements is vital for preventing oil spills. Creating an SPCC plan should be top priority for electric utility companies.

Secondary Containment Requirements

One of the EPA’s mandates is the use of secondary containment to prevent oil spills from polluting our nation’s navigable waterways which are defined under the Clean Water Act and Oil Pollution Act as any waterway or body of water that is used for interstate and foreign commerce, including lakes, rivers, streams, wetlands, wet meadows, play lakes and natural ponds. This description covers nearly all natural surface water in the United States. Oil is defined as petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes, non-petroleum oils, synthetics oils, animal fats, oil and greases and vegetable oils.

Once spilled, these materials pose a serious threat to soil, ground water, fresh water, marine habitats, human and animal life. Spilled oil is hazardous because:

  • It can contain low concentrations of benzene, toluene, ethyl benzene, sulfur and toxic metals.
  • All of these materials are poisonous to human and animal life if it has leaked into the ground water that replenishes our country’s wells or contaminates the surface water reservoirs where the water is ingested by humans or animals.
  • An oil spill is especially deadly to birds and water fowl because it coats their feathers so they are unable to fly and usually poisons them as they ingest it trying to clean their feathers.
  • An oil spill can also destroy most, if not all, of the vegetation adjacent to the waterway that is contaminated by it.
  • In addition, many of these chemicals can also present a significant fire hazard.

As a result, the EPA requires anyone who stores large quantities of oil in any of the forms described above to develop and implement an oil spill prevention, control and countermeasure (SPCC) plan. Justrite will work with you to help devise a means to meet secondary containment requirements.


Who is Affected by Secondary Containment Requirements?

Any containment facility with an above ground oil storage capacity greater than 1,320 gallons using storage media such as tanks, containers, drums, portable totes, transformers and other oil filled electrical equipment as well as any facility with underground tank storage capacity greater than 42,000 gallons must create and implement a SPCC plan to meet secondary containment requirements.

To qualify, the facility must be non-transportation related such as on and offshore drilling platforms, oil derricks and oil rigs, mobile oil drilling facilities, oil refineries, railroad car and truck oil tankers and their loading areas and loading equipment, oil pipelines and some waste treatment facilities. There must also be a real possibility that an oil spill can occur that will leak into navigable waters within the continental United States, along our coastlines or adjoining shorelines belonging to another country that can be affected by the oil spill.


SPCC Plans

A SPCC secondary containment plan must be developed in accordance with recommended engineering practices and approved by a company employee with the authority to implement the containment plan. To meet SPCC secondary containment requirements, each plan must also be tailored to the individual storage facility or media in use and must clearly address the following three areas of concern:

  • Operating procedures that will prevent oil spills.
  • Control measures for oil containment and to prevent an oil spill from reaching navigable waters.
  • Countermeasure for containment, clean up and to minimize any damage of an oil spill that does reach a navigable waterway.

A SPCC containment plan must be prepared by all facilities subject to regulation, have written management approval and be certified by a registered professional engineer. Not all SPCC plans have to be certified by a PE to meet secondary containment requirements; sites with less than 10,000 gallons can self-certify if they have not had any spills.

To qualify, the facility must be non-transportation related such as on and offshore drilling platforms, oil derricks and oil rigs, mobile oil drilling facilities, oil refineries, railroad car and truck oil tankers and their loading areas and loading equipment, oil pipelines and some waste treatment facilities. There must also be a real possibility that an oil spill can occur that will leak into navigable waters within the continental United States, along our coastlines or adjoining shorelines belonging to another country that can be affected by the oil spill.

A SPCC containment plan must contain the following information:

  • Identification of all oil storage media, where it is located, what its storage capacity is, what it is used for and how much is actually on hand.
  • Control measures to prevent an oil spill from reaching navigable waters.
  • Written descriptions of any past oil spills detailing the corrective actions taken and what secondary containment plans were implemented to prevent a re-occurrence.
  • A prediction of the direction, rate of flow and total quantity of oil that could be spilled based on past experience of potential equipment failures.
  • A description of any containment or diversionary structures and the equipment that is available to prevent a spill from reaching the waterway.
  • A detailed discussion of the spill prevention measures that apply to the specific facility and how these measure effect operations.
  • The operating procedures that have been implemented to prevent future oil spills from occurring.
  • Control measure in force to prevent future oil spills from reaching the waterway.
  • Implemented procedure and countermeasures to contain, clean-up and lessen the damage of any oil spill that does manage to reach the waterway.

SPCC Compliance and Secondary Containment Requirements

Any facility that spills more than 1,000 gallons of oil into navigable waters or onto a shoreline within a 12 month period, must submit the following information to the EPA Regional Administrator within 60 days from the time the chemical spill occurs for SPCC Compliance guidelines including the following information:

  • Facility name, location and date when the facility began operation.
  • Facility owner or operator names.
  • Facility maximum storage and/or handling capacity and normal daily oil throughput.
  • Copy of the complete SPCC plan including all amendments.
  • The cause of the spill including a failure analysis of the system or subsystem where the failure occurred.
  • Corrective actions or countermeasures taken such as repair or replacement of the failed equipment.
  • Preventative measures taken to prevent a re-occurrence.
  • Any additional information the Regional Director may request.
  • Implemented procedure and countermeasures to contain, clean-up and lessen the damage of any oil spill that does manage to reach the waterway.

Frequently Asked Questions

Do I need to contain 100 percent of the oil at my facility?

SPCC regulations state that the owner/operator needs to provide secondary containment for the "most likely" event. It is not likely that all the oil filled equipment would fail and drain at the same time. It is more likely that the largest oil-filled unit could fail and drain off. Most professional engineers feel that their SPCC Plan should be designed for the most likely event that would contain the amount of oil in the largest vessel, and which may or may not include enough freeboard to contain the oil plus a 25-year, 24-hour rain event. The latter depends on locations and annual rainfall figures

Visit the FAQ page to find more answers about secondary containment.

Question or Quote?