The Spill Prevention, Control, and Countermeasure (SPCC) rule under 40 CFR 112 requires facilities that store, handle, or use oil to develop and implement a plan to prevent oil discharges to navigable waters. Unlike routine tank or spill kit inspections, a program audit evaluates whether your overall SPCC plan is adequate, current, and properly implemented. EPA requires plan review and amendment whenever changes at the facility could affect the plan, and at least every five years through the Professional Engineer (PE) certification process.
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Download Checklist (.docx)Regulatory Requirements
EPA 40 CFR 112 — Oil Pollution Prevention
The SPCC rule applies to facilities with total aboveground oil storage capacity exceeding 1,320 gallons or underground storage exceeding 42,000 gallons that could reasonably be expected to discharge oil to navigable waters. The rule requires a written SPCC Plan, PE certification (for most facilities), secondary containment, oil handling procedures, inspections, training, and five-year plan reviews.
Clean Water Act Section 311
The SPCC rule implements Section 311(j)(1)(C) of the Clean Water Act, which authorizes EPA to require facilities to prepare and implement plans to prevent oil discharges. Violations can result in civil penalties up to $25,000 per day of violation and criminal penalties for knowing violations.
Facility Response Plan (FRP) — 40 CFR 112.20
Facilities meeting certain storage thresholds or that have experienced reportable discharges may also need a Facility Response Plan in addition to the SPCC Plan. Audit your FRP requirements alongside the SPCC program to ensure complete coverage.
Plan Documentation
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Plan availability | Current SPCC Plan is maintained at the facility and available for EPA inspection. Plan is accessible to all operating personnel. A copy is available at the facility 24/7, not just during business hours. |
| PE certification | Plan is certified by a licensed Professional Engineer (PE). PE certification is current and has been renewed within the last five years or after any significant amendment. Self-certified plans (Tier I qualified facilities) meet all eligibility criteria. |
| Five-year review | Plan has been reviewed and re-certified within the last five years per 40 CFR 112.5(b). Review date and PE signature are documented. If changes were needed, amendments were made and certified before implementation. |
| Facility diagram | Plan includes a facility diagram showing all oil storage containers, transfer stations, connecting piping, drainage patterns, secondary containment, and proximity to navigable waters. Diagram is current and reflects the actual facility layout. |
| Oil storage inventory | All oil storage containers are listed with type, capacity, and contents. Total facility storage capacity is accurately calculated. Underground and aboveground containers are listed separately. |
Secondary Containment
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Containment adequacy | Secondary containment is sized to hold the volume of the largest single container plus sufficient freeboard for precipitation. Bulk storage containers have dikes, berms, or retaining walls. Containment is impervious to oil and maintained in good condition. |
| Drainage controls | Containment areas have controlled drainage. Valves on containment drains are maintained in the closed position. Procedures exist for inspecting and draining accumulated stormwater. Discharge of contaminated water is prevented. |
| Loading/unloading areas | Transfer areas have spill containment or drainage to a central impoundment. Procedures require monitoring during transfers. Communication protocol between driver and facility operator is established. |
Operating Procedures
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Oil handling procedures | Written procedures exist for all oil handling operations including filling, transferring, and dispensing. Procedures address normal operations, startup, and shutdown. Overfill prevention measures are documented. |
| Inspection procedures | Routine inspection schedule is documented and being followed. Inspection records are maintained for at least three years. Inspection frequency meets 40 CFR 112.7(e) requirements. |
| Discharge notification | Procedures are in place for immediate notification of an oil discharge. Contact information for the National Response Center (1-800-424-8802), state agencies, and local responders is current and posted. |
| Personnel training | Oil handling personnel have received SPCC training. Training covers oil handling procedures, spill response, and discharge prevention. Training records are maintained and include dates, topics, and attendees. |
Facility Review
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Physical changes | All facility modifications since last plan review have been evaluated for SPCC impact. New tanks, piping changes, or operational changes are reflected in the plan. Plan amendment was completed within six months of any change. |
| Spill history | All spill events have been documented and reviewed. Root cause analysis was performed for each discharge. Plan amendments address any recurring issues. Reportable spill history is included in the plan. |
| Integrity testing | Bulk storage containers are on an integrity testing schedule per industry standards (API 653, STI SP001). Test results are documented and any identified deficiencies have been corrected. |
| Security measures | Oil storage areas have appropriate security measures including fencing, lighting, locks, and signage. Unauthorized access is prevented. Measures are documented in the plan. |
Corrective Actions
Common Issues and Responses
- Expired PE certification: Engage a licensed PE to review and re-certify the plan. Address any deficiencies identified during the review before certification.
- Missing five-year review: Schedule an immediate plan review with a PE. Document the review date and all findings. Amend the plan as needed and obtain new PE certification.
- Inadequate secondary containment: Engineering assessment of containment capacity is needed. Upgrade containment to meet 40 CFR 112 requirements. Consider interim measures such as portable containment while permanent solutions are implemented.
- Outdated facility diagram: Update the facility diagram to reflect current conditions. Verify all containers, piping, and drainage paths are accurately depicted. Include in the next plan amendment.
- Training gaps: Schedule SPCC training for all oil-handling personnel. Document training with attendance records, dates, and topics covered. Implement refresher training schedule.
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Download Checklist (.docx)Ecesis EHS Software
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