Spill Prevention, Control, and Countermeasure Plan
Regulations and Compliance

The Clean Water Act oil pollution regulations, issued in December of 1973, require certain oil storage facilities to prepare Spill Prevention, Control and Countermeasure plans. SPCC Plans for facilities are prepared and implemented as required by the U.S. Environmental Protection Agency (EPA) regulations as contained in Title 40, Code of Federal Regulations (CFR), Part 112 as amended through December 5, 2008.

The most recent amendments to the SPCC regulation require "liquid tight" containment systems. This requirement is compelling owners/operators to undertake significant upgrades to their facilities. The current EPA compliance deadline is November 10, 2010. EPA has indicated that they may extend the deadline into 2011.

Applicability of Federal SPCC Regulation

Non-transportation related facilities are subject to SPCC regulations if:
1) due to its location, the facility could reasonably be expected to discharge oil into or upon the navigable waters of the United States,
2) the total aboveground storage capacity exceeds 1,320 gallons which is calculated by the total of all containers on the site with a capacity of 55 gallons or more;
3) the completely buried storage capacity exceeds 42,000 gallons.

Overlapping State Regulations

Individual states can have regulations that create overlapping reporting requirements. For example, Connecticut has adopted the Federal SPCC Plan requirement whereas; Virginia has adopted the Oil Discharge Contingency Plan requirement that is separate from the Federal SPCC Plan requirement. One plan can be written to satisfy both the Federal and State requirements.

CCRG can assist with Federal and State compliance
by offering the following services:

  • Facility inspection and evaluation of required upgrades
  • Preparation of SPCC Plan
  • Engineering design for upgrades including civil, structural and geotechnical elements
  • Coordination of engineering and environmental concerns
  • Coordination of engineering submissions to meet local requirements
  • Preparation of bid documents and contractor selection
  • Construction oversight, final approvals and SPCC Plan addendums