Spill Prevention, Control, and Countermeasure (SPCC) Plan

You are tasked with drafting a comprehensive Spill Prevention, Control, and Countermeasure (SPCC) Plan that complies with 40 CFR Part 112 requirements under the Clean Water Act. This regulatory document must meet EPA standards for facilities that store oil in quantities that could reasonably be expected to discharge into navigable waters or adjoining shorelines.

Document Objectives and Regulatory Framework

Begin by establishing the plan's foundation with a clear introduction that identifies the facility's scope, ownership structure, and operational context. Explain the regulatory basis under 40 CFR Part 112, including whether the facility qualifies as a Tier I or Tier II facility, or requires a Professional Engineer certification. Research current EPA guidance documents and official SPCC rule interpretations to ensure the plan reflects the most recent regulatory requirements. The introduction should articulate specific plan objectives, including prevention of oil discharges, compliance with federal regulations, and protection of navigable waters and adjoining shorelines.

Facility Characterization and Site Analysis

Provide a detailed facility description that includes precise geographic coordinates, proximity to navigable waters, topographical features, and drainage patterns. Thoroughly examine any uploaded facility documents, site plans, engineering drawings, or previous environmental assessments to extract accurate information about the facility's physical layout, operational processes, and oil-handling activities. Describe all operations involving oil storage, transfer, or use, including production processes, loading/unloading operations, and any seasonal variations in activities. Identify and map all potential discharge pathways, including storm drains, ditches, culverts, and surface water flow patterns that could carry spilled oil to navigable waters. Cross-reference your findings with EPA's SPCC Guidance for Regional Inspectors and official facility templates to ensure completeness.

Comprehensive Oil Storage and Equipment Documentation

Create a complete inventory of all oil storage containers, tanks, piping systems, and transfer equipment at the facility. For each item, document the container type (aboveground storage tank, underground storage tank, mobile container, etc.), oil type and characteristics, maximum storage capacity, current typical volume, construction materials, age and condition, and precise location with reference to site maps. Research EPA best practices and industry standards for inventory documentation formats, ensuring the inventory meets the specificity required under 40 CFR 112.7. Include photographs, diagrams, or technical specifications where appropriate to support the written inventory.

Spill Prevention and Containment Systems

Detail all spill prevention measures implemented at the facility, organized by regulatory requirement category. Describe secondary containment systems for each storage area, including containment volume calculations demonstrating compliance with the requirement to hold 110% of the largest tank's capacity or 10% of total capacity, whichever is greater. Document overfill prevention systems, high-level alarms, automatic shutoff devices, and operational procedures that prevent tank overfilling during transfer operations. Explain general facility practices such as routine inspections, preventive maintenance programs, security measures, and personnel training that contribute to spill prevention. Research and cite specific regulatory requirements from 40 CFR 112.7 and subsequent subsections, verifying each citation against the current electronic Code of Federal Regulations to ensure accuracy. Include any facility-specific engineering controls, such as berms, dikes, curbing, drainage controls, or spill diversion systems.

Control, Countermeasure, and Response Procedures

Develop comprehensive procedures for detecting, controlling, and responding to oil spills of varying magnitudes. Describe spill detection methods, including visual inspections, automated monitoring systems, and employee reporting protocols. Outline immediate response actions for different spill scenarios, specifying containment strategies such as deploying absorbent materials, activating drainage controls, or implementing emergency shutdown procedures. Detail cleanup and recovery methods appropriate for the types of oil stored at the facility and the environmental conditions of the site. Research EPA's standard SPCC templates and industry best practices to ensure procedures align with regulatory expectations and proven response strategies. Include decision trees or flowcharts that guide personnel through response actions based on spill size, location, and environmental conditions.

Emergency Response Organization and Notification Protocols

Establish a clear emergency response organizational structure with defined roles and responsibilities for facility personnel. Identify the SPCC Coordinator or designated person with full authority to commit resources and implement emergency procedures. Specify notification procedures that comply with federal, state, and local requirements, including the National Response Center notification requirement for discharges that may reach navigable waters (as required by 40 CFR 112.4). Document coordination protocols with local emergency responders, fire departments, environmental agencies, and cleanup contractors. Review any existing site-specific emergency response plans in uploaded documents to ensure consistency and integration with the SPCC Plan. Research official EPA guidance and regulatory resources to verify that notification procedures meet all applicable legal requirements, including timing, content, and recipient specifications.

Training Programs and Inspection Schedules

Design a comprehensive training program that ensures all personnel involved in oil handling, storage, or spill response understand their responsibilities under the SPCC Plan. Specify training content, frequency, documentation requirements, and methods for evaluating training effectiveness. Address both initial training for new employees and refresher training for existing personnel. Establish detailed inspection schedules for all oil storage containers, transfer equipment, secondary containment systems, and spill response equipment. Research EPA SPCC training guidelines and industry standards to ensure the program meets regulatory expectations under 40 CFR 112.7(f). Document how inspection findings will be recorded, tracked, and addressed through corrective action procedures.

Recordkeeping, Documentation, and Plan Maintenance

Specify all recordkeeping requirements necessary to demonstrate ongoing compliance with the SPCC Plan and 40 CFR Part 112. Detail what records must be maintained, including inspection logs, training documentation, spill reports, equipment maintenance records, and plan amendments. Establish the plan review and update schedule, noting that plans must be reviewed and evaluated at least once every five years, and amended within six months of any changes that materially affect the facility's potential for oil discharges. Verify these requirements against current EPA regulations and official templates to ensure the recordkeeping system captures all necessary compliance documentation. Include provisions for maintaining records for the required retention period and ensuring availability for regulatory inspections.

Professional Certification and Regulatory Attestation

Prepare the appropriate certification statement based on facility classification. For facilities requiring Professional Engineer certification, include the PE certification language specified in 40 CFR 112.3(d), with space for the engineer's seal, signature, and registration number. For qualified facilities eligible for self-certification, include the owner/operator certification statement required by 40 CFR 112.6(a)(2). Research EPA's qualified facility templates and official guidance to ensure certification language precisely matches regulatory requirements. Include signature blocks for all required parties, with dates and titles clearly indicated.

Document Assembly and Quality Assurance

Once you have gathered all necessary information through document review, regulatory research, and verification of legal sources, compile the complete SPCC Plan in a professional format suitable for regulatory submission and facility implementation. Ensure all sections are internally consistent, all citations are accurate and properly formatted, all facility-specific information is complete and verified, and all regulatory requirements under 40 CFR Part 112 are addressed. The final document should be organized logically with a table of contents, numbered sections, and appendices for supporting documentation such as site diagrams, drainage maps, and equipment specifications. Create the document as a comprehensive, implementation-ready SPCC Plan that facility personnel can use for compliance and regulatory authorities can review for approval.