We explain the different types of SPCC plans that exist.
The other week we talked to an old client of ours. He was working at a new company and the facility he was in charge of needed an SPCC plan. Turned out, he got some bad advice from the facility's current consultant and turned to us for some clarification.
He knew there were some differences between the plans, but the advice the facility's current consultant was giving was totally wrong. The consultant said all plans need a Professional Engineer, and there's very little difference between the plans. We explained to him that you don't always need a PE to certify your SPCC plan, and that wasn't the case.
The issue here is folks generally know about SPCC plans but not the different types of them. Much like our friend, a lot of people know they'll need a plan, but not what type.
The different types of SPCC plans.
Simple enough, there are 3 different types of SPCC plans that apply to the vast majority of industrial, commercial, agricultural, and municipal facilities.
1. Tier I SPCC Plans
This type of plan applies to facilities that have at least 1,320-gallons, but less than 10,000-gallons of any type of oil or petroleum product on-site in aboveground storage tanks.
As long as all the aboveground tanks are smaller than 5,000-gallons, this plan applies to your facility.
This is a very simple plan to implement and use at your facility. It's short, concise, and can literally be created by anyone since this plan is self-certified.
That means you create it, you certify it's complete, accurate, and that practices are in place at the facility that will ensure your plan adheres to EPA requirements.
3. Full Professional Engineered Certified SPCC Plan
This plan applies to facilities that have over 10,000-gallons of oil or petroleum products, regardless of tank sizes. This plan is the biggest & most complex of the three.
While this plan can be prepared by anyone, only a professional engineer can review & certify the plan. A PE needs to certify the plan because they're signing off that the practices in place adhere to the EPA's regulations. As a side note, since this plan has to be certified by a PE, it goes without saying that this plan usually is the most expensive out of the main three.
So while a PE Certified SPCC plan is generally only for locations with over 10,000-gallons of oil or petroleum products, there are some other reasons why you may need to get a PE to certify your plan.
Oil Spills & SPCC Regulations
For instance, if you've had a spill on-site, or if your plan deviates from the regulations & requirements laid out in an SPCC plan, you're going to need a PE certified plan.
SPCC Plans & Underground Storage Tanks
There's another thing to remember, which is Full Professional Engineered Certified SPCC Plans are required for facilities that have underground storage tanks, or USTs, which can store at least 42,000-gallons of oil & petroleum products.
Also, these USTs in question cannot be subject to federal UST regulations. To be specific, underground storage tanks regulated under 40 CFR 280 and 281 are not subject to the SPCC regulations.
SPCC regulations can differ when you have a facility that has a lot of oil or petroleum stored on-site. And when I say a lot, I mean over 1,000,000-gallons. You're in a whole different ballpark, with different regulations.
Vessels (aka boats)
If you transfer oil or petroleum over water in vessels that have oil storage capacities of 42,000 gallons or more, you'll be subject to the Facility Response Plan (FRP) portion of the SPCC EPA requirements
This section of the regulations more or less states that plans must be approved by USEPA and/or the Coast Guard in order to be in compliance.
Guideline on Types of SPCC Plans
In order to break down SPCC plans into their simplest forms, they break down like this:
Tier I Plans – Over 1,320-gallons, less than 10,000-gallons, no tanks over 5,000-gallons.
Tier II Plans – Over 1,320-gallons, less than 10,000-gallons, at least one tank over 5,000-gallons.
Full PE Certified Plans – Over 10,000-gallons. Or, if you've had a spill. Or, if you deviate from the regulations. Or, if you have over 42,000-gallons in underground storage tanks.
Other Plans – 1,000,000-gallons or up, boats, and other unique circumstances.
So in reality, there are 3 main types of SPCC plans, with additional considerations for large facilities, and vessels. Simple enough, right?
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