SPCC Plan Requirements For Containers and Tanks

According to Section 112.1 of 40 CFR, the requirement for a Spill Prevention, Control and Countermeasure Plan (SPCC), applies to petroleum storage facilities that:

• Are non-transportation related.
• Have an aggregate above ground storage capacity greater than 1,320 gallons (including all tanks, containers, and operating equipment 55 gallons or greater in capacity) or a completely buried storage capacity greater than 42,000 gallons.
• Have a geographic location where there is a reasonable expectation of a discharge into or upon navigable waters of the US or adjoining shorelines.

Definition of Oil
Facilities that meet these three conditions must include bulk storage containers used to store oil in their SPCC Plan, if these containers have a capacity of 55 gallons or more. Oil is defined as:

• Petroleum products, including gasoline, diesel, and engine oil
• Animal fats
• Vegetable oils

In general, a plan is required for any non-transportation related onshore and off- shore facility that is engaged in drilling, producing, storing, gathering, processing, transferring, distributing, using, or consuming oil products.

When Can a Container Be Excluded From Your SPCC Plan?
A bulk storage container used to store oil that has a capacity of 55 gallons or greater may not require inclusion in the installation's SPCC Plan only under the following conditions:

• The container is part of a separate facility that must have a separate SPCC Plan.
• The container is part of a separate facility that does not have to prepare an SPCC Plan (a facility that does not meet the required criteria).

Requirements for a Diagram
There are many specific requirements outlined in 40 CFR 112 regarding your facility's Spill Prevention, Control, and Countermeasure Plan.

• Location of oil containers.
• Type of oil in each container.
• Location of any completely buried storage tanks that are otherwise exempted from SPCC regulations.
• Location of transfer stations and piping.
• Locations where mobile or portable containers are stored.

The SPCC Plan must include the storage capacity of each container but this does not have to be on the diagram.

Drawings and Photographs in the SPCC Plan
Site specific diagrams are not required if the facility diagram is explicit and complete. It must include:

• The direction of oil flow.
• The rate of flow.
• The total quantity of oil that could be discharged as a result of each type of major equipment failure. This may include loading/unloading equipment, tank rupture, overflow or leakage.

If site specific drawings or detailed facility drawings are included, illustrate:

• The predicted discharge direction on the drawing.
• Discuss the rate of flow and quantity of oil that could be discharged as a result of the different types of equipment failure.

Photographs are not required but they could assist in rapid recognition of the site layout. They can illustrate a visual history of the physical condition of the facility and/or the containers located there.