Environmental Compliance Course Materials
Last updated September 28, 2005

Complying with the Spill Prevention Control and Countermeasure Regulations

Many marinas and boatyards are required to have a Spill Prevention Control and Countermeasure (SPCC) plan for their facilities. An SPCC Plan is required by the federal Clean Water Act for facilities that store any kind of oil in certain volumes. The Plans purpose is to prevent the discharge of oil from a facility into navigable waters or adjoining shorelines. SPCC Plans require that your facility have adequate containment, such as berms and dikes around oil tanks to protect the soil and water in the event of a spill.

Your facility needs to develop a SPCC plan if it does any of the following:

• Stores oil above ground in any size tank(s) with a total aggregate volume over 1,320 gallons (containers of less than 55 gallons and/or permanently closed storage tanks are exempt from the total); or,
  
  
• Stores oil below ground in any size tank(s) with at total aggregate volume of 42,000 gallons (except for tanks that are compliant with the state requirement for USTs,) and,
  
  
• Could reasonably be expected to discharge oil to a "navigable water of the United States" or "adjoining shorelines" considering a possible worst-case scenario. (This criterion applies to just about every marina in the state, since a facility cannot take into consideration any man-made impediments to the flow of oil.)

Document your Determination

If you determine that your facility does not need an SPCC plan you need to have a licensed Professional Engineer (P.E.) prepare documentation that a plan is not required.


Prepare an SPCC Plan

If you determine that your facility does need an SPCC plan, you can either hire a P.E. to prepare the Plan or prepare one yourself and have it reviewed and certified by a P.E. Either way the plan must be prepared to comply with the requirements must include:

• Facility layout and drainage patterns
  
  
• List of all oil storage tanks and areas
  
  
• Quantities of oil that could be released, with predicted path of flow and flow rate
  
  
• Procedures for receiving oil from supplier, transfer of oil within the facility, end point uses of the oil, waste oil disposal
  
  
• Effects of a spill at the facility, fire hazards, employee evacuation, customer/neighbor considerations, press relations
  
  
• Capacity of required secondary containment devices. If it is not practicable to install secondary containment (i.e., a fuel dock), the owner/operator must explain why and provide a strong spill contingency plan, describing commitment to manpower, equipment, and materials to control and remove any harmful quantity of oil discharged
  
  
• Clean-up procedures, use of in-house staff versus contractors
  
  
• Notification list. Name(s) and phone numbers of in-house management, remote management, fire and police, municipal, state and federal agencies requiring notification
  
  
• Facility security for prevention of internal sabotage, external vandalism
  
  
• Employee training for spill prevention, oil handling, and spill clean-up. Only oil handling personnel must be trained in operation and maintenance of equipment to prevent oil discharge. Discharge prevention briefings for oil handling personnel must occur at least once a year
  
  
• OSHA considerations

Keep the SPCC Plan On-site

A copy of the SPCC plan must be maintained at any facility manned at least 4 hours per day. For remote locations, the SPCC plan should be filed at the nearest field office. A copy does not have to be filed with EPA or any other agency, unless it is a condition of a permit or license held by the facility. However, the SPCC plan must be available during normal business hours for review by an EPA inspector. EPA requires that facilities submit a copy of the SPCC plan to EPA Region 1 if a single spill of greater than 1,000 gallons occurs, or if two discharges of 42 gallons or more occurs within one year.

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