SPCC & SARA TITLE III

Spill, Prevention, Control and Countermeasure (SPCC) plans are an integral part of the Environmental Protection Agency’s oil spill prevention program. The federally mandated plans are designed to prepare you and your business for proper storage of oil products as well as how to proceed in the event of a release of those products.

SPCC plans are not an EPA requirement to ignore or take lightly, as doing either could result in a hearing before the EPA and substantial fines. CGRS Environmental Services has helped clients navigate enforcement actions following EPA inspections.

The EPA requires any facilities with aggregate aboveground oil storage capacity greater than 1,320 gallons to have a SPCC plan. The SPCC Plan protects the nation’s waters from contamination that affects all life downstream of an oil-based spill. The regulations apply to all facilities that store oil-based products such as petroleum, fuel or even milk fat in 55-gallon or bigger containers that cumulatively equate to greater than 1,320 gallons of product.

Sites that may need SPCC plans include bulk-fueling stations, agricultural facilities, dairies and milk-production plants, airports and more. CGRS Environmental Services can develop full SPCC plans that include the initial site inspection, describe tank testing and inspection requirements, and a SPCC plan that a professional engineer has reviewed and certified. Our inspections provide a complete assessment of current site equipment and associated spill-prevention measures and ensure they comply with the EPA’s current SPCC plan requirements.

CGRS SPCC inspections include:

  • Visiting project sites to perform site-specific SPCC inspections to identify any
    current or potential issues related to regulations including a detailed examination
    and inventory of containers or transfer equipment that contain oil-based products
  • Performing site mapping or site-map updates
  • Certifying a complete site-specific SPCC based on client-provided information
    and field-verified data by a licensed Professional Engineer

CGRS SPCC Plan outlines includes:

  • Manager-approved and professional engineer-certified plan
  • A detailed site diagram that describes discharge prevention, control, and
    countermeasure equipment and procedures, and procedures related to disposal
    and spill-response notification
  • Written procedures on performing regular inspections, guidelines on integrity
    testing and recordkeeping requirements
  • Describe training on SPCC plan requirements and procedures and list the
    facility’s designated spill-response contact personnel
  • Detail required security measures implemented at the facility to secure and control access to the tanks, related equipment and transfer equipment
  • Describe secondary containment required for tanks and tanker trucks in loading and unloading areas and measures taken to prevent spills from occurring during transfer
  • Identify measures taken to prevent uncontrolled product releases
  • Provide details on all applicable oil storage containers 55 gallons and greater in size, from compatibility with stored products to proper procedures to correct

SARA TITLE III: TIER II REPORTING

CGRS has extensive experience helping our clients meet this annual reporting requirement. We will complete and submit Tier II documentation for clients to the applicable state and Local Emergency Planning Committee (LEPC), as well as fire departments and county emergency response personnel agencies.