When is an SPCC Plan required, and how do you determine whether the SPCC rule applies to your facility?

In this episode of Tank Talk, “SPCC Applicability,” we break down the fundamentals of Spill Prevention, Control, and Countermeasure (SPCC) applicability under 40 CFR Part 112.

An SPCC Plan may be required when a facility is non-transportation-related, could reasonably be expected to discharge oil to navigable waters or adjoining shorelines in quantities that may be harmful, and exceeds applicable oil storage capacity thresholds.

In this episode, we discuss:

• The 1,320-gallon aboveground oil storage capacity threshold for SPCC applicability
• The 42,000-gallon completely buried oil storage capacity threshold
• Transportation-related vs. non-transportation-related facilities
• How the potential for a discharge to navigable waters affects SPCC applicability
• Which aboveground tanks and containers count toward oil storage capacity
• When regulated underground storage tanks are excluded
• How used oil, lubricants, hydraulic oil, fish oil, soybean oil, and other oils can factor into SPCC applicability
• Common misconceptions about determining whether a facility needs an SPCC Plan

We also explain why the 1,320-gallon SPCC threshold exists and how seemingly small containers of oil can push a facility over the applicability threshold.

If your facility stores oil and you aren't sure whether you need an SPCC Plan, this episode provides a practical starting point for understanding SPCC applicability and the factors that should be considered.

References & Resources:

40 CFR Part 112 – Oil Pollution Prevention
b_40cfr112.pdf

1971 EPA–DOT Memorandum of Understanding / Appendix A to 40 CFR Part 112
eCFR :: Appendix A to Part 112, Title 40 -- Memorandum of Understanding Between the Secretary of Transportation and the Administrator of the Environmental Protection Agency

EPA SPCC Guidance for Regional Inspectors
SPCC Guidance for Regional Inspectors | US EPA

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