SPCC for the Upstream Sector (Production, Drilling, and Workover)
Due to the danger oil spills cause for public health and the environment, every effort must be made to prevent oil spills and to clean them up promptly once they occur. The purpose of the Spill Prevention, Control, and Countermeasure (SPCC) rule is to help facilities prevent a discharge of oil into navigable waters or adjoining shorelines. A key element of the SPCC rule requires facilities to develop, maintain and implement an oil spill prevention plan, called an SPCC Plan. These plans help facilities prevent oil spill, as well as control a spill should one occur. If you have additional questions about the SPCC Program, please call our Oil Information Center at (800) 424-9346 or TDD (800) 553-7672.
Independent Petroleum Association of America's (IPAA) SPCC Guide (PDF) (63 pp, 491K, about PDF) - this guide was created by IPAA and is designed to help oil and gas producers understand the requirements of SPCC.
Create your SPCC Plan:
Tier I Template, is intended to help the owner or operator of a Tier I qualified facility develop a self-certified SPCC Plan.
To meet the Tier I applicability criteria, the facility must have:
- a total aboveground oil storage capacity of 10,000 U.S. gallons or less;
- no aboveground oil storage containers with a capacity greater than 5,000 U.S. gallons; and
- in the 3 years prior to the date the SPCC Plan is certified, had no single discharge of oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, or no two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 U.S. gallons within any 12-month period.*
State Professional Engineer (PE) licensing board contacts (PDF) (4 pp, 100K, about PDF) - This list will help you contact your state licensing board, which can then help you locate a PE should your plan require one.
EPA Region 8 Oil Regulations Workshops, May 1, 2012
Each workshop will cover the requirements for non-production and oil and gas production facilities subject to the SPCC rule, and an update on the status of EPA's revisions to the regulatory requirements for subject facilities. The workshops are identical. Workshops are free of charge, but you must register to attend. Both workshops will be held at the Utah Department of Environmental Quality/Division of Water Quality 195 North 1950 West 1st Floor Salt Lake City, UT 84116.
- Who is responsible for holding and maintaining an SPCC Plan?
- What if I can't meet the November 10, 2011, compliance date to prepare or amend my SPCC Plan?
- Is my facility covered by SPCC?
- How do I determine if my facility could reasonably discharge oil into or upon navigable waters or adjoining shorelines?
- If the oil storage capacity on the facility is less than 10,000 gallons total, can a facility self file a plan and do regular self-inspections and be in compliance?
1. Who is responsible for holding and maintaining an SPCC Plan?
The SPCC rule requires the owner or operator of the facility prepare and implement an SPCC Plan. The Plan must be maintained at the location of the facility that is normally attended at least 4 hours per day.
2. What if I can't meet the November 10, 2011, compliance date to prepare or amend my SPCC Plan?
The EPA Regional Administrator (RA) for the state where the facility is located may be able to provide a time extension to the facility to amend or prepare an SPCC Plan. Facilities who cannot meet the November 10, 2011, compliance date because a Professional Engineer (PE) isn't available, are located in areas impacted by floods, or that must make facility modifications that will not be completed in time, may request an extension by submitting a written request to the RA. Your request must include:
(i) An explanation of the cause for the delay and the specific aspects of the Plan affected by the delay;
(ii) A discussion of actions being taken or contemplated to minimize the delay; and
(iii) A proposed time schedule for the implementation of any corrective actions being taken, including interim dates for completion of tests or studies, installation and operation of any necessary equipment, or other preventive measures.
In addition you can provide additional oral or written statements in support of your extension request. To find out where to send your request, go to the list of regional EPA contacts available at http://www.epa.gov/emergencies/docs/oil/spcc/contact_list.pdf.
If you were required to have an SPCC Plan because you were operating before August 16, 2002, the RA may request a copy of your SPCC Plan to evaluate your extension request. The RA may grant an extension when he finds that a facility cannot fully comply with the SPCC requirements because either qualified personnel are not available, or there are delays in construction or equipment delivery beyond the control and without the fault of the facility.
Please note that facilities who submit an extension request must still comply with SPCC requirements. If the RA authorizes an extension of time for particular equipment or specific aspects of your Plan, you must still comply with the requirements related to other equipment or other specific aspects of your Plan for which the RA has not authorized an extension.
- Stores, transfers, uses or consumes oil or oil products, such as diesel fuel, gasoline, lube oil, hydraulic oil, adjuvant oil, crop oil, vegetable oil or animal fat; and
- Stores more than 1,320 US gallons in total of all aboveground containers (only count containers with 55 gallons or greater storage capacity) or more than 42,000 gallons in completely buried containers; and
- Could reasonably be expected to discharge oil to navigable waters of the US or adjoining shorelines, such as lakes, rivers and streams.
4. How do I determine if my facility could reasonably discharge oil into or upon navigable waters or adjoining shorelines? You can determine this by considering the geography and location of your facility relative to nearby navigable waters (such as lakes, rivers, streams, creeks and other waterways) or adjoining shorelines. You should consider if ditches, gullies, storm sewers or other drainage systems may transport an oil spill to nearby navigable waters or adjoining shorelines. Estimate the volume of oil that could be spilled in an incident and how that oil might drain or flow from your facility and the soil conditions or geographic features that might affect the flow toward navigable waters or adjoining shorelines. Also you may want to consider whether precipitation runoff could transport oil into navigable waters or adjoining shorelines. You may not take into account manmade features, such as dikes, equipment, or other structures that might prevent, contain, hinder, or restrain the flow of oil. Assume these manmade features are not present when making your determination. If you consider the applicable factors described above and determine a spill can reasonably flow to a waterway, navigable water or adjoining shorelines, then you must comply with the SPCC rule.
5. If the oil storage capacity on the facility is less than 10,000 gallons total, can a facility self file a plan and do regular self-inspections and be in compliance? Yes, and you do not have to file the plan with EPA. If over 10,000 gallons in total oil storage capacity, you will need a professional engineer to certify your plan.
- Letter from API on Natural Gas Processing Facilities (PDF) (5 pp, 45K, about PDF)
- Response to API on Natural Gas Processing Facilities (PDF) (2 pp, 625K, about PDF)