What Is the Spill Prevention Control and Countermeasure (SPCC) Rule?

I recently came across a staggering statistic: there are approximately 542,000 underground storage tanks (USTs) across the United States holding petroleum and hazardous substances. On top of that, there are an estimated 600,000 aboveground storage tanks (ASTs), most of which are used by the oil and gas industry. That’s a massive amount of oil and chemicals being stored—and with that comes significant risk.

So how does the government keep tabs on all these tanks and prevent potential disasters? The answer lies in the Spill Prevention, Control, and Countermeasure (SPCC) Rule, a key component of the oil pollution prevention regulations designed to safeguard our waters from oil contamination.

In this article, I’ll break down everything you need to know about the SPCC Rule, from its purpose and history to how it applies to facilities storing oil.

Key Takeaways

• The SPCC Rule prevents oil spills from contaminating navigable waters through proactive planning and measures.

• Facilities storing oil above specific thresholds must create an SPCC Plan tailored to their operations and risks.

• SPCC certification, by a PE or self-certified, verifies the plan’s compliance and effectiveness for preventing and managing spills.

• Failure to update SPCC Plans risks penalties, liability, and increased environmental harm due to outdated prevention measures.

What Is the SPCC Rule?

The SPCC rule, or the Spill Prevention, Control, and Countermeasure, is a federal regulation introduced in 1973 by the U.S. Environmental Protection Agency (EPA) under the authority of Section 311 of the Clean Water Act (CWA). Its primary focus is to prevent oil spills from reaching navigable waters and adjoining shorelines.

Unlike reactive measures, the SPCC Rule emphasizes prevention. The SPCC rule requires facilities to have the necessary infrastructure, detailed procedures, and regular SPCC training programs in place to reduce the likelihood of spills. In cases where spills do occur, the SPCC Rule ensures facilities are prepared to respond quickly and effectively, minimizing harm to the environment.

This regulation serves as a critical framework for facilities storing significant amounts of oil, mandating the development of comprehensive SPCC plans that address spill risks, prevention strategies, and emergency response protocols.

Related Environmental and Safety Regulations

What Is the SPCC Plan?

An SPCC Plan  is a facility-specific document that outlines how a facility will prevent oil spills, control them if they occur, and limit environmental damage. In practice, the SPCC Plan acts as a roadmap for responsible oil management. It emphasizes preparation, accountability, and proactive measures to prevent oil spills, while also equipping facilities with the tools and knowledge they need to respond effectively in the event of a spill. 

Facilities subject to the SPCC Rule are categorized into three main types based on their oil storage capacity and spill history. These categories determine the type of SPCC Plan a facility must prepare, the level of detail required, and whether a Professional Engineer (PE) must certify the oil spill prevention plan. Let’s break down the types of SPCC Plans:

This table provides a clear comparison of the three SPCC Plan types, helping facilities quickly identify their category and the requirements they need to meet.

What Does an SPCC Plan Contain?

The SPCC Plan is not a one-size-fits-all template. Every facility subject to the SPCC Rule must create a plan based on its unique layout, operational processes, and oil storage capacity. According to 40 CFR §112.7, each SPCC Plan must detail the following components:

1. Facility Layout: Includes diagrams or maps showing oil storage containers, transfer areas, and potential pathways for spills to reach navigable waters.

2. Spill Pathways and Impact Analysis: Identifies areas where a spill could occur and assesses the likely environmental impact.

3. Preventive Practices: Details methods to reduce the risk of spills, such as secondary containment systems, regular equipment inspections, and proper storage procedures.

4. Emergency Response Procedures: Clearly lays out the steps to take during a spill, including who to contact and what actions to prioritize.

5. Maintenance and Inspection Schedules: Specifies how often equipment, storage containers, and safety measures must be inspected and maintained.

6. SPCC Training: Describes the training programs required for employees who handle oil or oversee storage facilities.

This individualized approach helps address the specific risks of oil spills at that facility, making the plan both actionable and relevant.

Who Is Responsible for Certifying the SPCC Plan?

A Professional Engineer (PE) is typically required to certify an SPCC plan. The PE’s role is to verify that the plan complies with EPA standards and is tailored to the specific needs and risks of the facility. As part of the certification process, the PE reviews the plan to confirm that:

• • The plan is prepared following SPCC regulations.

  • The preventive measures and controls described in the plan are appropriate for the facility’s risks and layout.

  • The plan is technically sound, ensuring the facility can prevent and respond to spills effectively.

There is, however, an important exception: smaller facilities with a total oil storage capacity of less than 10,000 gallons may self-certify their SPCC Plans, provided they meet certain conditions. To qualify for self-certification, the facility must:

• • Have a clean spill history, with no oil discharges exceeding the thresholds specified by the EPA within the last three years.

  • Comply with all other requirements outlined in the SPCC Rule.

Self-certification can reduce costs and streamline the process, but it comes with added responsibility. Facility owners must have a thorough understanding of the SPCC requirements and implement the plan effectively to maintain compliance and ensure safety.

In summary, certification—whether by a PE or through self-certification—verifies that the SPCC Plan meets regulatory standards and that its measures are appropriate for addressing the facility’s unique spill prevention and response needs.

When Is an SPCC Plan Required?

An SPCC Plan is required when a facility meets specific thresholds for oil storage capacity and poses a risk of discharging oil into navigable waters or adjoining shorelines. The EPA has established clear criteria to determine whether a facility falls under the SPCC Rule. Understanding these requirements is essential for determining your compliance obligations.

Oil Storage Capacity Thresholds

The need for an SPCC Plan is triggered by the total oil storage capacity at a facility, not the actual amount of oil stored. The thresholds are as follows:

• • Aboveground Storage Tanks (ASTs): A facility must prepare an SPCC Plan if it has an aggregate aboveground oil storage capacity of greater than 1,320 gallons. This includes oil stored in containers with a capacity of 55 gallons or more.

  • Underground Storage Tanks (USTs): An SPCC Plan is required for facilities with underground oil storage tanks exceeding 42,000 gallons, provided they are not already regulated under other programs like the Underground Storage Tank program.

It’s worth noting that these thresholds apply to the facility’s total storage capacity, so even if containers are empty or partially filled, they still count toward the total. For more information on SPCC applicability, visit www.epa.gov.

Types of Facilities Covered

The SPCC Rule applies to a broad range of industries and facilities that store or handle oil. Examples include:

• • Oil Refineries and Bulk Storage Terminals: Facilities that store large volumes of oil for commercial distribution.

  • Farms: Operations with fuel storage tanks for agricultural equipment.

  • Manufacturing Plants: Facilities that store oil in production processes or equipment.

  • Marinas: Locations that store oil for fueling boats and marine equipment.

  • Utility Companies: Sites that store oil for backup generators or transformers.

If a facility has the potential to discharge oil into navigable waters or shorelines, it is likely subject to the SPCC Rule, regardless of its primary industry.

Exemptions

Not all facilities that store oil are required to have an SPCC Plan. Key exemptions include:

• • Small Containers: Oil containers with a capacity of less than 55 gallons are not counted toward the storage threshold.

  • Completely Buried USTs Regulated by Other Programs: USTs already regulated under the Underground Storage Tank program are generally exempt.

  • Certain Residential Uses: Residential heating oil tanks are typically excluded unless they pose a risk to navigable waters.

While these exemptions provide relief for some, facilities should carefully evaluate their storage practices and the proximity of their operations to water sources to confirm whether an SPCC Plan is needed.

What Needs to Be Inspected According to SPCC Regulations?

The SPCC rule emphasizes regular inspections as a critical component of spill prevention and control. Facilities covered by the SPCC Rule are required to conduct routine inspections of their oil storage equipment, infrastructure, and containment measures to identify and address potential issues before they lead to spills. Here’s a detailed breakdown of what needs to be inspected under SPCC regulations:

How Often Do SPCC Plans Need to Be Updated?

An SPCC Plan must be updated within six months of any significant changes at the facility that could affect oil storage or spill prevention measures. These changes include:

• • Modifying the layout of the facility, such as adding or removing oil storage containers.

  • Increasing or decreasing the facility’s total oil storage capacity.

  • Introducing new equipment or operational processes that could impact spill risks.

  • Relocating existing containers or making changes to secondary containment systems.

The updated plan should address the new risks and include revised diagrams, procedures, and preventive measures. Even if no changes occur, SPCC Plans must be reviewed at east once every five years. During this review, the facility should:

• • Reassess the accuracy of the plan, including facility diagrams and descriptions.

  • Evaluate whether existing preventive measures and spill response procedures are still appropriate.

  • Update employee training schedules and contact information for emergency responders.

If no updates are needed after the five-year review, the facility should document the review to demonstrate compliance. However, failing to update an SPCC Plan when required can have serious consequences: outdated or ineffective spill prevention measures increase the risk of environmental damage. Additionally, non-compliance with the SPCC Rule can result in legal repercussions, including regulatory penalties and liability for spills—especially if the plan no longer reflects current risks or operations.

SPCC FAQs

What is 40 CFR Part 112?

40 CFR Part 112 is the section of federal regulations under the EPA that outlines the requirements of the Spill Prevention, Control, and Countermeasure (SPCC) Rule. It governs how facilities must prevent, control, and respond to oil spills to protect navigable waters and adjoining shorelines.

What are the 3 C's of spill control?

The 3 C's of spill control are Control, Contain, and Clean Up. These steps guide the immediate actions taken to manage and mitigate the effects of an oil spill.

What is the purpose of the SPCC regulation?

The purpose of the SPCC regulation is to prevent oil spills from facilities that store oil and mitigate the environmental damage if spills occur. Its goal is to protect navigable waters and shorelines from oil contamination.

What is one effective method of spill countermeasures?

One effective spill countermeasure is the use of secondary containment systems, such as berms or dikes, to prevent spilled oil from reaching the environment. These systems provide a physical barrier to control and isolate spills.

What is a spill prevention plan?

A spill prevention plan is a documented strategy that outlines measures to reduce the likelihood of oil spills and procedures to respond effectively if a spill occurs. It is a key component of compliance under the SPCC Rule for facilities handling oil.

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