Overview: The Spill Prevention, Control, and Countermeasure (SPCC) Guidance for Regional Inspectors U.S. Environmental Protection Agency Office of Solid

Overview: Overview: The Spill Prevention, Control, and The Spill Prevention, Control, and Countermeasure (SPCC) Countermeasure (SPCC) Guidance for Regional InspectorsGuidance for Regional Inspectors

U.S. Environmental Protection AgencyU.S. Environmental Protection AgencyOffice of Solid Waste and Emergency ResponseOffice of Solid Waste and Emergency Response

Office of Emergency ManagementOffice of Emergency Management

Overview: SPCC Guidance for Regional Inspectors

SPCC Guidance DocumentSPCC Guidance Document Is intended to assist regional inspectors in

reviewing a facility’s implementation of the SPCC rule

Establishes a consistent understanding among regional EPA inspectors on how particular provisions of the rule may be applied

Available as a guide to owners and operators of facilities and the general public

This slideshow presents an overview of the topics covered in the Guidance Document.

The full document is available at www.epa.gov/oilspill


DisclaimerDisclaimer

The statutory provisions and EPA regulations described in this guidance document contain legally binding requirements. The guidance document does not substitute for statutory provisions or regulations, nor is it a regulation itself.

While the guidance document indicates EPA's strongly preferred approach to assure effective implementation of legal requirements, EPA decisionmakers retain the discretion to adopt approaches on a case-by-case basis that differ from this guidance where appropriate.

EPA welcomes public comments on the document at any time and will consider those comments in any future revision of the guidance document.


Guidance Document ContentsGuidance Document Contents

Chapter 1:Chapter 1: Introduction Introduction

Chapter 2:Chapter 2: Applicability of the SPCC Rule Applicability of the SPCC Rule

Chapter 3:Chapter 3: Environment Equivalence Environment Equivalence

Chapter 4:Chapter 4: Secondary Containment and Secondary Containment and Impracticability DeterminationsImpracticability Determinations

Chapter 5:Chapter 5: Oil/Water Separators Oil/Water Separators

Chapter 6:Chapter 6: Facility Diagrams Facility Diagrams

Chapter 7:Chapter 7: Inspection, Evaluation, and Testing Inspection, Evaluation, and Testing

AppendicesAppendices


Chapter 1: IntroductionChapter 1: Introduction

SPCC BackgroundSPCC Background

– Purpose and scopePurpose and scope

– Statutory frameworkStatutory framework

Regulatory HistoryRegulatory History

– Initial promulgationInitial promulgation

– Proposed revisionsProposed revisions

Overview of 2002 Revised Rule ProvisionsOverview of 2002 Revised Rule Provisions Using the Guidance DocumentUsing the Guidance Document


Using the Guidance DocumentUsing the Guidance Document

Clarifies the role of the inspector in Clarifies the role of the inspector in reviewing implementation of performance-reviewing implementation of performance-based provisionsbased provisions

Is a “living document” and may be Is a “living document” and may be updated or revisedupdated or revised

Does not address all aspects of the SPCC Does not address all aspects of the SPCC rulerule


Chapter 2: ApplicabilityChapter 2: Applicability

Applicability criteria:Applicability criteria:– Definition of “oil” and activities involving oil Definition of “oil” and activities involving oil

– Definition of “facility”Definition of “facility”

– ““Non-transportation-related” facilities – Non-transportation-related” facilities – EPA/DOT jurisdictionEPA/DOT jurisdiction

– Definition of “discharge”Definition of “discharge”

– Reasonable expectation of discharge to Reasonable expectation of discharge to navigable waters in quantities that may be navigable waters in quantities that may be harmfulharmful

– Regulated storage capacityRegulated storage capacity

– Various exemptionsVarious exemptions


Applicability, Applicability, continuedcontinued

Regional AdministratorRegional Administrator– Process for an RA to apply the SPCC rule to an Process for an RA to apply the SPCC rule to an

otherwise exempted facilityotherwise exempted facility

– Appeals processAppeals process

Different types of containersDifferent types of containers– Bulk storage containers and oil-filled Bulk storage containers and oil-filled

equipmentequipment

Applicability of facility response plan Applicability of facility response plan requirementsrequirements

Summary of SPCC Applicability


Chapter 3: Environmental Chapter 3: Environmental EquivalenceEquivalence

The “environmental equivalence” provision The “environmental equivalence” provision allows facilities to implement alternate measures allows facilities to implement alternate measures based on site-specific considerationsbased on site-specific considerations

– Measures must provide equivalent environmental Measures must provide equivalent environmental protection, in accordance with good engineering protection, in accordance with good engineering practice and as determined by a Professional practice and as determined by a Professional EngineerEngineer..

Lists the substantive requirements eligible for the Lists the substantive requirements eligible for the provision, clarifies certain policy areas, and provision, clarifies certain policy areas, and provides examplesprovides examples

Describes the role of EPA inspector in reviewing Describes the role of EPA inspector in reviewing deviations based on environmental equivalencedeviations based on environmental equivalence


Environmental Equivalence,Environmental Equivalence, continuedcontinued

Additional guidance on environmentally Additional guidance on environmentally equivalent measures for specific equivalent measures for specific requirements:requirements:

– SecuritySecurity

– Facility drainageFacility drainage

– Corrosion protection and leak testing of Corrosion protection and leak testing of completely buried metallic storage tankscompletely buried metallic storage tanks

– Overfill preventionOverfill prevention

– PipingPiping

– Evaluation, inspection, and testingEvaluation, inspection, and testing


Chapter 4: Secondary Containment Chapter 4: Secondary Containment and Impracticability Determinationsand Impracticability Determinations

Overview of secondary containment provisionsOverview of secondary containment provisions– Example methods of containmentExample methods of containment

General vs. specific provisionsGeneral vs. specific provisions Sufficient freeboardSufficient freeboard

– Sample calculations of containment sizingSample calculations of containment sizing

Passive vs. active measuresPassive vs. active measures– Examples of when each approach may be appropriateExamples of when each approach may be appropriate

““Sufficiently impervious”Sufficiently impervious” Facility drainage requirementsFacility drainage requirements


Categories of Secondary Categories of Secondary Containment RequirementsContainment Requirements

General Provision, §112.7(c)General Provision, §112.7(c)– Addresses the potential for oil discharges from all Addresses the potential for oil discharges from all

regulated parts of a facilityregulated parts of a facility– Containment method, design, and capacity are Containment method, design, and capacity are

determined by good engineering practice to determined by good engineering practice to contain an oil discharge until clean-up occurs.contain an oil discharge until clean-up occurs.

Specific Provisions Specific Provisions – Address the potential of oil discharges from Address the potential of oil discharges from

specific parts of a facility where oil is stored or specific parts of a facility where oil is stored or handled. handled.

– Containment design, sizing, and freeboard Containment design, sizing, and freeboard requirements are specified by the SPCC rule to requirements are specified by the SPCC rule to address a major container failure.address a major container failure.


Impracticability DeterminationsImpracticability Determinations Additional requirements that accompany an Additional requirements that accompany an

impracticability determinationimpracticability determination Documentation needed Documentation needed Detail on impracticability determinations for Detail on impracticability determinations for

certain areas:certain areas:– Piping and flowlinesPiping and flowlines

– Transfer areasTransfer areas

– Oil-filled EquipmentOil-filled Equipment

– Loading/unloading racksLoading/unloading racks

– Onshore bulk storage containersOnshore bulk storage containers

– Mobile/portable containersMobile/portable containers

– Bulk storage containers at production facilitiesBulk storage containers at production facilities

– Onshore drilling and workover equipmentOnshore drilling and workover equipment


Chapter 5: Oil/Water SeparatorsChapter 5: Oil/Water Separators

Provides applicable SPCC requirements Provides applicable SPCC requirements for oil/water separators used for:for oil/water separators used for:– Wastewater treatment Wastewater treatment – Secondary containment Secondary containment

– Oil productionOil production


SPCC Requirements for Oil/Water SPCC Requirements for Oil/Water Separator UsesSeparator Uses

Wastewater Wastewater Treatment UseTreatment Use

Secondary Secondary Containment UseContainment Use

Oil Production UseOil Production Use

Separators are Separators are exempt from all exempt from all SPCC requirements SPCC requirements in accordance with in accordance with §112.1(d)(6) and do §112.1(d)(6) and do not count toward not count toward facility storage facility storage capacity.capacity.

Separators which are Separators which are used as part of a used as part of a secondary secondary containment system containment system and are not intended and are not intended for oil storage or use for oil storage or use are subject to are subject to applicable secondary applicable secondary containment containment requirements and do requirements and do not count toward not count toward storage capacity.storage capacity.

Separators are bulk Separators are bulk storage containers, storage containers, subject to the subject to the provisions of provisions of §§112.9(c) or §§112.9(c) or 112.11(d), and count 112.11(d), and count toward the overall toward the overall facility storage facility storage capacity. They are capacity. They are not exempt.not exempt.


This chapter discusses:This chapter discusses:– The purpose of the facility diagram The purpose of the facility diagram

– Required and recommended elements of a Required and recommended elements of a facility diagramfacility diagram

– Necessary level of detailNecessary level of detail

– Approaches for specific types of equipmentApproaches for specific types of equipment

Provides example facility diagramsProvides example facility diagrams

Chapter 6: Facility DiagramsChapter 6: Facility Diagrams


Overview of the inspection, evaluation, and Overview of the inspection, evaluation, and testing requirements testing requirements

Specific requirements for:Specific requirements for:

– Integrity testing and visual inspection Integrity testing and visual inspection

– Brittle fracture evaluationBrittle fracture evaluation

– Inspections of pipingInspections of piping

– Flowline maintenanceFlowline maintenance

Chapter 7: Inspection, Evaluation, Chapter 7: Inspection, Evaluation, and Testingand Testing


Inspection, Evaluation, and Inspection, Evaluation, and Testing, Testing, continuedcontinued

Specific casesSpecific cases– Aboveground bulk storage container for Aboveground bulk storage container for

which the baseline condition which the baseline condition isis known known

– Aboveground bulk storage container for Aboveground bulk storage container for which the baseline condition which the baseline condition is notis not known known

– Deviation from integrity testing requirements Deviation from integrity testing requirements based on environmental equivalencebased on environmental equivalence

Summary of industry standards, code Summary of industry standards, code requirements, and recommended practices requirements, and recommended practices that apply to different types of equipmentthat apply to different types of equipment


Role of the EPA InspectorRole of the EPA Inspector

Each chapter describes:Each chapter describes:– Appropriate documentation that the owner/operator Appropriate documentation that the owner/operator

should include in SPCC Planshould include in SPCC Plan

– What EPA inspectors should look for both in the Plan What EPA inspectors should look for both in the Plan and in the field to determine compliance with the SPCC and in the field to determine compliance with the SPCC rulerule

If the inspector questions the appropriateness of If the inspector questions the appropriateness of alternative measures, he/she should fully document alternative measures, he/she should fully document all observations and other pertinent information for all observations and other pertinent information for further review by the regional staff. Follow-up action further review by the regional staff. Follow-up action by the EPA inspector may include requesting by the EPA inspector may include requesting additional information from the facility owner or additional information from the facility owner or operator.operator.


AppendicesAppendices

A.A. Text of CWA 311(j)(1)(c)Text of CWA 311(j)(1)(c)

B.B. Text of 40 CFR Part 112Text of 40 CFR Part 112

C.C. Summary of Revised Rule ProvisionsSummary of Revised Rule Provisions

D.D. Sample Bulk Storage Facility SPCC PlanSample Bulk Storage Facility SPCC Plan

E.E. Sample Production Facility SPCC PlanSample Production Facility SPCC Plan

F.F. Sample Contingency PlanSample Contingency Plan

G.G. SPCC Inspection ChecklistsSPCC Inspection Checklists

H.H. Other Policy DocumentsOther Policy Documents


Sample PlansSample Plans

Example SPCC Plans for bulk storage and Example SPCC Plans for bulk storage and oil production facilitiesoil production facilities

– Show appropriate format and level of detailShow appropriate format and level of detail

– Can be adapted to fit a facility’s site-Can be adapted to fit a facility’s site-specific characteristicsspecific characteristics

Example Contingency PlanExample Contingency Plan

– Prepared according to the requirements of Prepared according to the requirements of 40 CFR part 10940 CFR part 109


For EPA inspectors to record observations For EPA inspectors to record observations during the site visit and review of the during the site visit and review of the SPCC PlanSPCC Plan

Provides room for inspector comments Provides room for inspector comments and photos of the facilityand photos of the facility

Helps achieve the goal of national Helps achieve the goal of national consistency in inspectionsconsistency in inspections

SPCC Inspection ChecklistsSPCC Inspection Checklists


Additional InformationAdditional Information

The Guidance Document and The Guidance Document and additional information is additional information is available on the U.S. EPA Oil available on the U.S. EPA Oil Program Web site, Program Web site, www.epa.gov/oilspillwww.epa.gov/oilspill

Call the TRI, EPCRA, Call the TRI, EPCRA, RMP and Oil RMP and Oil Information Call Center Information Call Center at at 1-800-424-93461-800-424-9346