After reviewing hundreds of SPCC plans through our compliance assistance program, the OCA has identified the five most common errors that lead to plan deficiencies during EPA inspections. Here’s how to avoid them.
Mistake #1: Incorrect Capacity Calculations
Many facilities undercount their total aboveground oil storage capacity, sometimes inadvertently falling into a higher regulatory tier. Common omissions include: drums stored temporarily on-site, mobile equipment fuel tanks, emergency generator fuel storage, hydraulic fluid reservoirs on large equipment, and oil-filled electrical transformers.
The Fix: Conduct a comprehensive oil inventory that includes every container, vessel, and equipment tank at the facility. Update the inventory at least annually. When in doubt, include it.
Mistake #2: Inadequate Secondary Containment Sizing
The most technically common deficiency: containment systems that are too small. The rule requires 110% of the largest single container, but many plans incorrectly calculate this as 100%, or fail to account for accumulated rainwater reducing the effective containment volume.
The Fix: Calculate containment requirements at 110% minimum. For outdoor containment in areas with significant precipitation, consider designing to 150% to account for potential rainwater accumulation between drainage events.
Mistake #3: Outdated Plans
SPCC plans must be reviewed and if necessary amended whenever there is a change in facility design, construction, operation, or maintenance that affects the potential for an oil discharge. Many facilities fail to update their plans after adding storage tanks, changing processes, or modifying containment structures.
The Fix: Establish a formal management of change procedure that triggers SPCC plan review for any significant facility modification. Schedule annual plan reviews even in the absence of changes.
Mistake #4: Missing or Inadequate Inspection Documentation
The SPCC rule requires periodic inspections of containment systems, and those inspections must be documented. During EPA inspections, auditors routinely find inspection logs that are missing, incomplete, or not linked to corrective action records when deficiencies were noted.
The Fix: Implement a formal inspection program with standardized checklists, designated responsible personnel, and a closed-loop corrective action system. Digital inspection platforms can significantly improve compliance in this area.
Mistake #5: Undertrained Personnel
SPCC regulations require that oil-handling personnel understand the regulations, the facility’s SPCC plan, and their roles in spill prevention and response. Training records must be maintained. Many facilities have plans that satisfy the regulatory requirements on paper, but personnel don’t know what to do in an actual emergency.
The Fix: Implement annual SPCC training for all oil-handling personnel. Conduct at least one spill drill per year. Document all training with sign-in sheets and test results. OCA offers online and in-person SPCC training programs through our Certified Containment Specialist program.