Serving the Oil & Gas Industry


SPCC Defined

The United States Environmental Protection Agency (EPA) Spill Prevention, Control and Countermeasure (SPCC) rule applies to owners or operators of nontransportation related facilities that drill, produce, store, refine, transfer, distribute, use or consume oil or oil products and have an aggregate aboveground storage capacity of greater than 1,320 gallons that could reasonably be expected to discharge oil to navigable waters or adjoining shoreline. As a cornerstone of EPA's strategy to prevent oil spills from reaching our nation's waters, the Agency requires that certain facilities develop and implement SPCC Plans. Unlike oil spill contingency plans that typically address spill cleanup measures after a spill has occurred, SPCC plans ensure that facilities put in place containment and other counter measures that would prevent oil spills that could reach navigable waters (e.g., berms surrounding the oil storage tank). Under EPA's Oil Pollution Prevention regulation, facilities must detail and implement spill prevention and control measures in their SPCC Plans.

Facility Inspections

EPA Regional personnel, or contract personnel, periodically go on-site to inspect facilities subject to the Oil Pollution Prevention regulation. In many cases, EPA notifies the facility owner or operator of the inspection prior to arriving at the facility. Announced inspections ensure the availability of appropriate facility personnel and build a conducive working relationship between the Agency and the facility. However, EPA occasionally conducts unannounced facility inspections in order to gauge a facility's preparedness to prevent or respond to an oil spill. Once at the facility, EPA inspectors may ask to review the SPCC Plan and the Facility Response Plan and conduct a walk-through inspection of the facility to ensure that the facility has implemented spill prevention and response measures. In addition, EPA may interview facility personnel on the SPCC and Facility Response Plans and their role in implementing them. In some cases, the EPA finds that facilities are in compliance; however, when the Agency encounters a facility that violates the oil spill prevention regulations, EPA has the authority under the Clean Water Act to assess an administrative penalty.

How ESR Can Help

A regulated facility must comply with the SPCC Final rule or risk EPA-imposed risk penalties for noncompliance. ESR personnel will assess facility specific information and determine applicable SPCC compliance requirements. Part of this determination involves:

  • Visit facility and prepare detailed oil storage inventory
  • Prepare facility diagram, including site layout, drainage features, oil storage detail and containment
  • Prepare SPCC inspection checklist to ensure continued compliance
  • Prepare and finalize the SPCC plan
  • Provide facility inspections and employee training