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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We’re heading back into the Tank Talk archives for a conversation that’s still an important one for anyone managing bulk fuel storage: how do SPCC plans and STI SP001 inspections work together?

In this episode, Shannon breaks down the connection between SPCC requirements and tank inspection programs, including why STI SP001 is commonly used as the industry standard for many facilities. She walks through the difference between routine in-house inspections and inspections performed by a certified STI inspector, what can trigger additional inspection requirements, and why keeping good inspection records matters.

We also dig into what to look for when an STI inspection report comes back - from secondary containment and overfill prevention to inspection intervals - and why meeting the STI standard doesn’t automatically mean every SPCC requirement has been satisfied.

Plus, Shannon explains how these requirements can extend beyond traditional tanks to portable containers such as drums and totes, and where facility managers can find additional inspection guidance and resources.

Whether you’re reviewing your SPCC plan, managing an existing inspection program, or trying to make sense of when your tanks are due for inspection, this episode is a good one to keep in your compliance toolbox.

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You receive your updated SPCC Plan and notice a compliance table attached ... now what?

In this episode of Tank Talk, Shannon and Haley break down one of the most misunderstood parts of an SPCC Plan: the compliance table (sometimes called implementation items). They discuss what these findings mean, why they exist, and what facility managers should do after receiving one.

You'll learn:

• What an SPCC compliance table actually is
• The difference between required and recommended items
• How to prioritize corrective actions
• Why documenting progress matters
• Some of the most common compliance issues found during SPCC inspections

Plus, we've created a downloadable SPCC Compliance Quick Reference Guide (https://www.integrity-env.com/spcc-basics-compliance-tables) to help you prioritize findings and stay on track toward compliance.

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