Question 1

What is the SPCC threshold for requiring a plan?

Accepted Answer

Under EPA 40 CFR Part 112, a facility must have an SPCC plan if it stores more than 1,320 gallons of oil in aggregate aboveground storage capacity (counting only containers of 55 gallons or more) or more than 42,000 gallons in completely buried underground tanks. The facility must also have a reasonable expectation of discharging oil to navigable waters.

Question 2

What counts as oil under SPCC regulations?

Accepted Answer

The EPA defines oil very broadly under SPCC: petroleum products (diesel, gasoline, heating oil), lubricating oils, hydraulic fluids, transformer/dielectric oils, used/waste oil, cooking oils, vegetable oils, animal fats, biodiesel, and synthetic oils. Natural gas is not included, but natural gas condensate is.

Question 3

Can I self-certify my SPCC plan without a Professional Engineer?

Accepted Answer

Yes, if your facility qualifies as a Qualified Facility: total aboveground oil storage of 10,000 gallons or less, no single discharge over 1,000 gallons in the past 3 years, and no two discharges over 42 gallons each in any 12-month period. Tier I facilities (no container over 5,000 gallons) can use the EPA template. Tier II facilities must write a full plan but can still self-certify.

Question 4

What are the penalties for not having an SPCC plan?

Accepted Answer

EPA can assess civil penalties of up to $25,000 or more per day per violation for SPCC non-compliance, even if no spill has occurred. A 2011 EPA study found 55% of regulated facilities were non-compliant. Penalties are adjusted annually for inflation and can escalate to millions for major spill events caused by negligence.