Accurate Facility Diagram

Include all tanks, drums, loading areas, and transfer stations.

Show drainage patterns and secondary containment systems.

Oil Storage Inventory

Document type, quantity, and location of all oil containers >55 gallons.

Include both aboveground and underground storage (with certain exceptions).

Secondary Containment

Use dikes, berms, double-walled tanks, or spill pallets.

Ensure containment capacity is 110% of the largest container or as required.

Spill Pathway Evaluation

Assess potential spill routes to navigable waters.

Include stormwater systems, drainage ditches, etc.

Inspection & Maintenance

Regular Inspections

Perform visual inspections weekly or monthly (as specified).

Look for leaks, corrosion, and structural integrity issues.

Tank Integrity Testing

Follow industry standards (e.g., STI SP001, API 653).

Frequency depends on tank size, construction, and containment features.

Containment Maintenance

Remove rainwater promptly from diked areas.

Test water before discharge to ensure it’s oil-free.

Training & Personnel

Employee Training

Conduct annual SPCC training for all relevant personnel.

Include spill response, inspection procedures, and reporting.

Designated SPCC Coordinator

Assign a primary person responsible for implementation and oversight.

Provide 24/7 contact information.

Documentation & Recordkeeping

Keep Records for 3 Years

Inspection logs, training records, discharge reports, and plan revisions.

SPCC Plan Certification

Must be certified by a Professional Engineer (PE), unless eligible for self-certification.

Five-Year Review

Review and update the plan at least once every five years or after significant changes.

Emergency Response

Spill Response Plan

Include procedures for containment, cleanup, and notification.

Stock adequate spill response equipment on site.

Emergency Contacts

List internal and external contacts (e.g., NRC, local fire department).

Discharge Notification

Any discharge into navigable waters must be reported to the National Response Center (NRC) immediately: 1-800-424-8802

Common Pitfalls to Avoid

Incomplete diagrams or missing containers.

Lack of secondary containment for transfer areas.

Not updating the plan after facility changes.

Infrequent or undocumented inspections.

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