Serving Louisiana, Arkansas, Oklahoma, New Mexico, Texas and 65 Tribes

Contact Us Search: All EPA This Area

• You are here: EPA Home
• Region 6
• Superfund
> Outreach Guides - Oil Pollution > SPCC Bulk Storage

SPCC Requirements and Pollution Prevention Practices for Bulk Storage Facilities

Overview

This guide will assist bulk oil storage facilities with the prevention and control of oil spills. Other guides have been developed to assist other industry sectors in the regulated community. This guide discusses the equipment and operating practices needed to meet the requirements of the Federal Oil Pollution Prevention Regulation found in Title 40 Code of Federal Regulations (CFR) Part 112, which includes the Spill Prevention Control and Countermeasure (SPCC) Plan requirements and the Facility Response Plan (FRP) requirements. The SPCC requirements are the focus of this guide; other guides are available for the facility response planning requirements (40 CFR 112.20 and 112.21) and general information on the Oil Pollution Prevention Regulation.

Recommended practices for pollution prevention and avoiding discharges of oil are also included in this guide. These practices may also assist facilities in achieving compliance with the SPCC requirements and reduce the possibility of product loss and a discharge.

---

* A discharge is essentially a spill that reaches a navigable water or adjoining shoreline. The legal definition can be found in 40 CFR 112.2(b).

Applicability of the SPCC Requirements to Bulk Oil Storage Facilities

EPA's SPCC requirements (40 CFR 112.1 through 112.7) apply to nontransportation-related facilities that could reasonably be expected to discharge oil into or upon the navigable waters of the United States or adjoining shorelines, and that have (1) a total underground buried storage capacity of more than 42,000 gallons; or (2) a total aboveground oil storage capacity of more than 1,320 gallons, or (3) an aboveground oil storage capacity of more than 660 gallons in a single container.

Some facilities may not be regulated if, due to their location, they could not reasonably be expected to discharge oil into navigable waters of the U.S. or adjoining shorelines. SPCC-regulated facilities must also comply with other federal, state, or local laws, some of which may be more stringent.

Many bulk oil storage facilities are subject to the SPCC regulation, and some may be subject to the Facility Response Plan (FRP) regulation under 40 CFR 112.20 and 112.21. All owners or operators of SPCC-subject facilities should determine whether the facility poses a threat of substantial harm to the environment. As outlined in 40 CFR 112.20(f)(1), a facility has the potential to cause substantial harm if:

The facility transfers oil over water to or from vessels and has a total oil storage capacity, including both aboveground storage tanks (ASTs) and underground storage tanks (USTs), greater than or equal to 42,000 gallons; or

The facility's total oil storage capacity, including both ASTs and USTs, is greater than or equal to one million gallons, and one of the following is true:

• The facility lacks secondary containment that is able to contain the capacity of the largest AST within each storage area plus freeboard to allow for precipitation;
• The facility is located at a distance such that a discharge could cause injury to an environmentally sensitive area;
• The facility is located at a distance such that a discharge would shut down a public drinking water intake; or
• The facility has had a reportable spill greater than or equal to 10,000 gallons within the last five years.

All facilities must document the determination of substantial harm by completing the "Certification of the Applicability of the Substantial Harm Criteria Checklist," provided as Attachment C-II in Appendix C of 40 CFR 112. This certification should be kept with the facility's SPCC plan. Click here to find out the definition of navigable waters or oil.

SPCC and Specific Spill Prevention Requirements for Bulk Storage Facilities

---

SPCC: Preparation and Certification [40 CFR 112.3]

---

The owner or operator of an SPCC-subject facility is required to have a written site-specific spill prevention plan, which details how a facility's operations comply with the requirements of 40 CFR 112.

Requirements for specific elements to be included in the SPCC plan are found in 40 CFR 112.7. The SPCC plan must be reviewed and certified by a Registered Professional Engineer who is familiar with SPCC and has examined the facility. To be in compliance, the facility's SPCC plan must satisfy all of the applicable requirements for drainage, bulk storage tanks, tank car and truck loading and unloading, transfer operations (intrafacility piping), inspections and records, security, and training. Most importantly, the facility must fully implement the SPCC plan. Newly constructed facilities and facilities that make modifications must prepare or revise their SPCC plan within six months. Modifications may include, for example, changes in piping arrangements or installation or removal of tanks.

---

Containment and Diversionary Structures Appropriate for Bulk Storage Facilities
[40 CFR 112.7(c)]

---

SPCC requires containment of drainage from the operating areas of a facility to prevent oil spills and contaminated runoff from reaching storm drains, streams (perennial or intermittent), ditches, rivers, bays, and other navigable waters.

Secondary containment and diversionary structures should be in place to contain oil-contaminated drainage (e.g., rainwater) or leaks around fuel dispensers, pipelines, valves, joints, transfer connections, and tanks. For these purposes, facilities should use dikes, berms, curbing, culverts, gutters, trenches, absorbent material, retention ponds, weirs, booms, and other barriers or equivalent preventive systems. SPCC requirements are performance-based, which permits facility owners and operators to substitute alternative forms of spill containment if the substitute provides substantially equivalent protection against discharges to navigable waters to that provided by the systems listed in 40 CFR 112.7(c).

The secondary containment structure must be impervious and must prevent water and fuel from percolating through the soil, contaminating the soil and groundwater and possibly surfacing aboveground into navigable waters or adjoining shorelines.

Substantially equivalent containment systems may be possible for AST systems (e.g., small double-walled ASTs equipped with spill prevention devices) that generally have capacities of less than 12,000 gallons. Alternative containment systems may not be appropriate for tank systems larger than 12,000 gallons or for systems that consist of several tanks connected by manifolds or other piping arrangements that would permit a volume of oil greater than the capacity of one tank to be spilled as a result of a single system failure.

---

Facility Drainage [40 CFR 112.7(e)(1)]

---

Diked Areas

Facilities most often use poured concrete walls or earthen berms to contain drainage and provide secondary containment for storage tanks and curbing and catchment basins for truck loading/unloading areas. These contained areas are considered diked areas. Concrete and earthen dike containment structures around storage tanks may accumulate significant amounts of water. Drain lines, which must be watertight, are usually installed through the dike walls and are used to drain accumulated stormwater from the diked area. These lines should be fitted with valves or other positive means of closure that are normally sealed closed and locked to prevent any oil discharges from escaping the diked area. The valves must be open-close manual valves; flapper valves are not acceptable.

These valves must be opened to drain rainwater and resealed following drainage by trained and authorized facility personnel only. Adequate records must be kept of such drainage events (i.e., date, time, personnel names) and made part of the SPCC plan. The accumulated rainwater must be examined and determined to be free of oil contamination before diked areas are drained. If any oil sheen or accumulation of oil is observed, an alternate method of draining the diked area must be employed. The contaminated water may be diverted to an onsite treatment plant or oil-water separator; however, the adequacy of these systems is determined on a case-by-case basis for each one's adherence to good engineering practices and ability to retain a spill in the event of a system malfunction.

Bulk storage facilities may employ many different types and designs of drainage control systems and oil-water separators. Facilities must implement a system that is consistent with good engineering practices, based on the size and complexity of their operations.

One design may consist of a sump located inside a containment area, which may be a blind sump (no drains) or a sump restrained by a normally closed valve. Facilities may remove the floating oil product by manual skimming or using sorbent materials. These materials must be disposed of properly or recovered for reuse. Any oil removed from skimming or the sorbent material must be disposed of as a waste oil. The remaining water in the sump must be inspected before discharging it outside the containment areas. Once sufficiently inspected and found to be free of oil, the water may be discharged by authorized personnel as long as the discharge is supervised and documented.

Other facilities may use a completely or partially buried oil-water separator system equipped with an inlet valve and a weir and baffle system, which directs the oil to one compartment and the water to another. The oil-water separator must never automatically discharge treated water to a sanitary sewer or anywhere outside a contained area.

Another alternative is to pump out diked areas with a manual pump or vacuum truck. Any oil-contaminated water must be transported to an appropriate waste-handling facility for disposal or treated on site.

---

Undiked Areas

Other operating areas of a bulk storage facility that do not have secondary containment systems specifically designed for those areas (otherwise referred to as "localized containment") are considered undiked areas. Drainage must be controlled for these areas which may include: tank car and truck loading/unloading areas, truck or engine washdown areas, piping and manifold areas, garage bays, and fuel islands. All undiked areas can be designed to control drainage through a combination of curbing, trenches, catchment basins, and retention ponds, as necessary to retain a spill. These structures must be inspected and examined for integrity and their effectiveness. For example, if a paved area is improperly graded or if a curb is deteriorating, contaminated water may escape from the facility. For this reason, a professional Engineer must certify the SPCC plan to ensure that the drainage system is adequately designed and properly maintained in accordance with good engineering practices.

Whatever techniques are used, the facility's drainage systems should be adequately engineered to prevent oil from reaching navigable waters in the event of equipment failure or human error at the facility.

---

Oil Storage: Bulk Storage Tanks, Portable Tanks, Drums, and Oil-Containing Equipment [40 CFR 112.7(e)(2)]

---

Many types of units are used to store oil products. Storage containers or tanks may be located aboveground, underground, partially underground, and inside buildings.

---

Tank Material

No tank should be used for the storage of oil unless its construction material is compatible with the material stored and conditions of storage such as pressure, physical and chemical properties, and temperatures.

It is recommended that the construction, materials, installation, and use of tanks conform with relevant portions of industry standards, such as American Petroleum Institute (API), National Fire Protection Association (NFPA), Underwriters Laboratory (UL), or American Society of Mechanical Engineers (ASME), which may be required in the application of good engineering practices or by state or local regulations.

---

Secondary Containment

All storage containers (e.g., tanks, oil-water separators) must have secondary containment for the entire contents of the largest single container within the containment area, plus sufficient freeboard to allow for precipitation. An alternative system could consist of a complete drainage trench enclosure arranged so that a spill could terminate and be safely confined in a catchment basin. The containment structure must be sufficiently impervious to the types of oil products stored at a facility. Diked areas should be free of pooled oil; spills should be removed promptly.

The volume of freeboard should be based on regional rainfall patterns. Facilities in states with large amounts of rainfall (e.g., Washington, Alaska, and Hawaii, and the Commonwealth of Puerto Rico) will require secondary containment to accommodate greater amounts of water.

Precipitation data is available from the National Oceanic and Atmospheric Administration's (NOAA) National Climatic Data Center (NCDC). The NCDC can be reached by telephone at (828) 271-4800 and at http://www.ncdc.noaa.gov/oa/climate/research/monitoring.html on the worldwide web.

The following table describes the most common secondary containment systems.

---

Tank Integrity - Inspections and Testing

ASTs should be properly maintained to prevent oil leaking from bolts, gaskets, rivets, seams, and any other part of the tank. The older riveted or bolted steel tanks tend to "weep" oil from rivets and bolts.

Personnel should note visible oil leaks on an inspection form and report them to the person in charge of spill prevention. Leaks should be repaired immediately. In some cases, the product in the tank will require removal.

Another area of concern for ASTs is tank bottom deterioration. Tank bottoms may be subject to extensive corrosion, which may not be evident during visual inspections. Measures must be taken to prevent this corrosion based on the type of tank installation and tank foundation. Corrosion protection can be provided by dielectric coatings and carefully engineered cathodic protection. Some facilities have installed double-bottom tanks to reduce the corrosion factor.

Corrosion of a tank's surface may also result in tank failure. Corrosion that is concentrated in small areas of a tank's surface or "pitting" creates a high potential for tank failure. If tanks are rusty, holes may form causing the tank to leak. Tank supports and foundations should also be inspected for cracks, crumbling, deterioration, and seepage.

ASTs should be subjected to periodic integrity testing. Some of the accepted methods for testing are the following:

• X-ray or radiographic analysis measures wall thickness and detects cracks and crevices in metal.
• Ultrasonic analysis measures shell metal thickness.
• Hydrostatic testing shows leaks caused by pressure.
• Visual inspection detects some cracks, leaks, or holes.
• Magnetic flux eddy current test used in conjunction with ultrasonic analysis detects pitting.

---

Internal Heating Coils

Internal steam-heating coils are sometimes used in heavy oil tanks to maintain the oil in a fluid, less viscous state in cold weather. The deterioration of the steam-heating coils from internal corrosion can result in product leakage when oil drains through a corroded coil to discharge into a nearby waterway. To control leakage through defective internal heating coils, the following factors should be applied:

• The steam return or exhaust lines from internal heating coils that discharge into an open water course should be monitored for contamination or routed to a settling tank, skimmer, or other separation system to remove oil;
• Consider using external heating coils and insulating the sides of the tank if necessary. Because of the problems encountered with internal steam-heating coils, there has been a movement away from their use to more modern external heat-exchanger systems.

---

Fail-Safe Devices - Level Gauging Systems and Alarms

Bulk storage facilities must take precautions to ensure that tanks are not overfilled. There are two basic objectives for using a fail-safe system:

• prevent the tank from overfilling and spilling liquid.
• prevent damage to the tank.

Level gauging systems must be selected in accordance with good engineering practices based on the size and complexity of operations at a facility. It is not adequate to only "stick" a tank. A second overfill protection measure should be used as a backup. Some trucks have automatic shutoff systems, which shut off the pump once the meter reaches the volume of product that has been determined to be a safe fill level (e.g., 90% of capacity). Larger tanks may be designed with gauges, high-level alarms, and high-high level alarms to satisfy this requirement. The following table provides examples of some acceptable systems.

Level Gauging Systems and Alarms
Type of System	Description
Direct Sight Level Gauges	In the simplest case, the gauge is a small-diameter glass or plastic tube vertically attached to two openings in the tank shell. Liquid level in the tank is shown by the level in the tube. Another common sight level gauge is a float gauge. A float rides on top of the liquid in the tank and moves a marker attached to a cable or chain on the outside of the tank. The marker moves up or down with the product level in the tank.
Digital Computers or Telepulse	Telepulse is a simple and accurate system for remote supervision of storage tank liquid levels and temperatures. The unit consists of a transmitter and receiver to relay and receive tank temperature and product level readings. Digital computers can be tied in to display data at more than one location. Portable fill alarm systems are also available that can be used while liquid cargoes are transferred from a storage container into a transportation vehicle. Many variations of these systems are in use.
High Liquid Level Alarms	High liquid level alarms are usually tied into a float gauge or level gauging system. The alarms produce an audible or visual signal when the liquid level in the tank reaches a predetermined height. In older systems, a simple sound is produced by air motion; this is called an audible air vent.
High Liquid Level Pump Cutoffs	This consists of a fill-level alarm connected to a pump control that automatically shuts down the pump when a preset liquid level is reached. This system eliminates the possibility of human failure and is effective at stopping overfilling of tanks.
Direct Audible/Code Signal Communication	This system consists of communication between the tank gauger and pumping station and relies on human perception of liquid levels in the tanks and pumping rates to avoid overfilling tanks. Human error could cause a spill if the tank gauger or pumping station misreads an audible or code signal to start or stop pumping. Communication between the gauger and pump station is usually through two-way radio.
Additional Safety Features	Relief valves and overflow lines are part of safety and level control systems on most petroleum storage tanks. Valves for pressure and vacuum relief will prevent tank damage but may result in a spill or discharge of liquid. Excess liquid may be allowed to flow into another tank through an overflow line. Vacuum vents prevent a tank from collapsing when liquid is pumped out of the tank.

---

Types of Aboveground Storage Tanks and Appurtenances

ASTs come in a variety of designs. Atmospheric tanks used for storing petroleum products are designed to contain pressures of 0 to 0.5 psig. There are five common types of atmospheric storage tanks used for petroleum products: fixed cone roof tank, floating roof tank, fixed vertical roof tank, vapor dome roof tank, and lifter roof tank. Floating roof tanks minimize vapor loss because the roof rests on the liquid, which greatly reduces the vapor space between the top of the tank and the top of the liquid. Lifter roof or vapor dome tanks reduce the amount of vapor loss by moving up or down with vapor volume changes. Ordinary fixed cone roof tanks and vertical roof tanks tend to have higher vapor loss than the other three types. Aboveground tanks often are painted with aluminum or white paint to reflect heat, which decreases the temperature rise of the liquid contents and slows evaporation. The thickness of the metal used for tank construction is based on the strength required to hold the mass of the liquid. There is also an added allowance for corrosion encountered during the service life of the tank. Storage tanks should be constructed of materials compatible with the contents contained in the tank. Steel tanks resist heat from exposure to fires and maintain structural integrity for a longer period of time than any other material currently used for tank construction.

Low pressure (0-15 psig) storage tanks are commonly used for storing petroleum products with low vapor pressures. Low pressure tanks are designed to contain liquids with vapor pressures slightly higher than atmospheric pressure, but not exceeding 15 psig. Spheroid and horizontal tanks are the two common types used for petroleum products; however, spheroid tanks are normally used for storing very "light" hydrocarbons, such as pentane, butane, and propane, which do not present a spill hazard if released. Horizontal tanks are used for storing products such as light crude oil, gasoline additives, gasoline blending stocks, and naphtha solvents which constitute a spill hazard if released. Most horizontal tanks are constructed of welded steel, but some older riveted steel tanks may still be in service. Horizontal storage tanks should be frequently examined for cracks, corrosion, buckling, or other damage.

---

Underground Storage Tanks

When compared to ASTs, USTs have some advantages for storing petroleum products, such as reduced vapor loss, increased safety, efficient land use and greater security. The obvious disadvantages are undetected leaks and higher corrosion factors for metal tanks. Fiberglass-reinforced plastic tanks are commonly used for storing petroleum products underground. They have a distinct advantage over metal tanks in being corrosion-free. Corrosion-resistant coatings are also available.

Steel USTs should be protected from corrosion by coatings, cathodic protection, or other effective methods compatible with local soil conditions. Underground corrosion of metal surfaces is a direct result of an electric current that is generated by the reaction between the metal surfaces and chemicals present in the soil and water. The flow of current from one portion of the tank to another causes metal ions to leave the surface of the metal, creating pits. The rate of destruction of the metal is directly related to soil moisture and chemical makeup.

All USTs should also be subjected to regular pressure testing and adequate records must be kept of such tests. These records must be made part of the SPCC plan and kept for at least three years.

The Federal UST regulations found in 40 CFR 280 have technical requirements consistent with the underlying regulatory purposes of the SPCC program and are equally protective for purposes of preventing discharges of oil into waters of the United States. These regulations contain provisions for corrosion protection, leak detection, tank overfill and spill prevention equipment, and tank tightness testing. Facilities should refer to the full text of 40 CFR 280 when making determinations of compliance.

---

Partially Buried Storage Tanks

Partially buried metallic storage tanks used for petroleum storage should be avoided unless the buried section of the shell is adequately coated. Partial burial in damp earth can cause rapid corrosion of metallic surfaces due to water collecting at the soil surface. Protective corrosion-resistant coatings and cathodic protection should be used to prevent corrosion. Partially buried tanks are considered to be aboveground tanks and are subject to the same requirements as other aboveground tanks under the provisions of 40 CFR 112 due to their potential threat to surface waters. Click here to find additional information on cathodic protection .

---

Portable Oil Storage Containers

Mobile or portable oil storage tanks (including trucks containing product), 55-gallon drums, and other small containers should be positioned or located so as to prevent spilled oil from reaching navigable waters. A secondary means of containment, such as dikes, basins, or spill pallets, must be provided. The containment area must hold the contents of the largest container stored in the area. Many facilities keep drums and portable oil tanks inside covered, contained warehouse storage areas. It is best to have a covered area to reduce exposure to the elements so that the containers remain in good condition and runoff is eliminated.

These storage areas must be located where they will not be subject to periodic flooding or washout.

Containment for drums and other small containers does not have to be expensive. If there are a small number of drums, a facility may purchase spill pallets or portable containment devices (e.g., overpack drums) designed for drum containment.

---

Transfer Operations: Hosing, Pipelines, and Joints [40 CFR 112.7(e)(3)]

---

Transfer operations consist of piping, valves, gauges, regulators, compressors, pumps and other mechanical devices used to transfer oil from one area to another within a facility. Pipelines used to transport oil for interstate or intrastate commerce are considered transportation-related systems and are regulated under the DOT OPS program. Pipelines which are used for the transport of oil exclusively within the confines of a nontransportation-related facility are regulated under the SPCC program. Some of the more common mechanical transfer systems are the piping systems required to transfer product between tanks and railcar or truck loading and unloading areas.

SPCC requires that the terminal connection at the transfer point be capped or blank-flanged and marked as to origin for a pipeline that is not in service or in standby service for an extended time. Aboveground pipe supports should be designed and spaced in order to prevent sagging, minimize abrasion and corrosion, and allow for expansion and contraction.

Buried piping must have a protective wrapping and coating, and should be cathodically protected if used in corrosive soil conditions. If any section of buried piping is exposed for any reason, it must be examined for deterioration and corrosion and repaired, if necessary. Obviously, buried piping cannot be visually examined and must be subjected to periodic pressure testing, regardless of materials of construction. Plastic or fiberglass-reinforced pipes do not require protective coatings or cathodic protection.

---

Inspections of Aboveground Pipes, Valves, and Pumps

All aboveground pipes and valves should be regularly examined on a scheduled basis by operating personnel. Flange joints, expansion joints, valve glands and bodies, and metal surfaces should be evaluated. Piping in high spill probability areas should be periodically subjected to pressure testing. Pipes, valves, and connecting joints should be free of leaks, drips, and oil-saturated soil underneath. Defective or leaking equipment should be replaced or repaired, and adequate records should be made of such repairs. All records should be made part of the SPCC plan and kept for at least three years.

Pumps, valves, and gauges are covered under the same regulations as piping. They must be regularly examined by facility personnel. They should be free of leaks, drips, or any defects which could lead to a spill. Soil underneath pumps, valves, and connections should be free of oil stains or pooled oil. Flow valves must be periodically packed with grease to prevent leakage, and gaskets must be replaced periodically. Pumps require periodic rebuilding and connecting lines need to be resealed to prevent leaks.

---

Warning Signs for Aboveground Pipes

Drivers granted entry into a facility must be verbally cautioned or warned by appropriate signs to assure that their vehicle, because of its size, will not endanger aboveground piping or hosing. Tank truck loading/unloading areas should have appropriate protection for aboveground pipes (e.g., bumper poles) and adequate signs posted to warn drivers of the presence of aboveground pipes in traffic areas.

---

Tank Car and Tank Truck Loading and Unloading Procedures [40 CFR 112.7(e)(4)]

---

Product loading and unloading operations include fueling activities by customers at gas stations and cardlock facilities, and the receipt of product from tank cars, tank trucks or smaller carriers. Fueling terminals, islands, and other loading areas must meet the same requirements as the unloading areas of a facility.

---

DOT Procedures

Regardless of the types of trucks servicing a facility, all drivers must follow loading/ unloading procedures established by the Department of Transportation (DOT) in 49 CFR 171, 173, 174, 177, and 179. Training programs should thoroughly address these requirements and procedures should be incorporated into a Standard Operating Procedures (SOP) manual for product transfer. Moreover, facilities should consider ways to ensure that other commercial drivers or contractors are competent in these procedures (e.g., issue driver certifications).

---

Secondary Containment

Due to their function, tank car (railcar) and truck loading/ unloading areas have a high probability for spills. Secondary containment systems should be designed specifically for a facility's topography configuration, and the size of the tank car/truck loading or unloading at the site.

Loading/unloading areas typically are designed to permit vehicle access and incorporate a secondary containment system. The most common loading/ unloading area containment system is a covered, curbed, and graded area that drains to a sump. Drainage should flow into retention ponds, catchment basins, or treatment systems designed to retain oil or return it to the facility. A method to clean or retain oily stormwater or return it to the facility from loading/unloading areas must also be considered. A system that incorporates good engineering practices minimizes the volume of water, ice and snow that enters the containment area.

The containment system must be designed to hold the maximum capacity of the largest compartment of a tank car or truck loaded or unloaded at the facility. As an example, if a 9,000-gallon tanker truck has three 3,000-gallon compartments, the loading area containment should hold at least 3,000 gallons. If there are separate areas for different unloading or loading operations, each area should be designed specifically to hold the capacity of the largest carrier anticipated to conduct operations in that area. For facilities that load or unload from "unit trains," the containment system must be capable of containing the aggregate volume of product for all open railcars/ compartments linked to the manifold in a series for product transfer at the same time. An engineer must look at the entire facility as a unit to determine the adequacy of the spill containment systems in place.

---

Warning or Barrier System

An interlocked warning light or physical barrier system (such as a brake-interlock system for bottom-loading trucks) or warning signs should be provided in loading and unloading areas to prevent a vehicle from leaving before being completely disconnected from the fuel transfer lines.

Prior to filling and departure of a tank car or truck, the lowermost drain and all outlets of such vehicles should be closely examined for leakage. If necessary, valves should be tightened, adjusted, or replaced to prevent leaking in transit.

---

Inspections and Records [40 CFR 112.7(e)(8)]

---

Inspections help prevent spills due to equipment or containment system failure. Adequate inspection and maintenance programs are a critical component of a spill prevention program. Inspection and maintenance records provide the only real evidence of compliance testing of storage tanks, piping, level gauging systems, alarms and related equipment.

Records of inspection procedures (including frequencies of inspections), maintenance, and draining of diked areas should be included in the facility's SPCC plan.

Records of drainage of diked areas are important in determining a facility's compliance, especially when drainage flows directly into a navigable waterway and bypasses in-plant treatment systems.

The following table includes the types of records that should be maintained at a facility. Such records must be kept for a minimum of three years.

Inspection and Maintenance Program Records
Aboveground Storage Tanks and Piping	Regular visual inspections and/or tank integrity testing (e.g., shell thickness testing). Pipe supports, pipes, valves and pumps (regular visual inspections). Piping in high risk spill areas (periodic pressure testing). Storage tank flow valves, supports, foundations (regular visual inspections). Storage tank level gauges and alarms (regular mechanical function testing/visual inspections).
Underground Storage Tanks and Piping	pressure testing of tanks and piping. Inventory monitoring for leaks. Testing of cathodic protection system.
Dikes, Berms, Secondary Containment Systems	Containment dikes and berm integrity (regular visual inspections). Records of drainage of rainwater from diked containment areas (must be recorded whenever areas are drained). Rainwater must be free of oil sheen. Date, time, and signature of employee who performed drainage and/or manager.

---

Security [40 CFR 112.7(e)(9)]

---

Security is critical to preventing accidental releases or vandalism by the public. The security measures required under SPCC are simple precautions that greatly reduce the risks of vandalism and undetected spills.

The perimeter of a facility should be protected with good lighting, fencing, and locked gates. Motion detectors and video cameras may be used for added security. Access to the facility should be restricted during nonbusiness hours. Starter controls for fuel pumps should be locked. Any valves that will allow the direct outflow of product are also required to be locked (e.g., water draw-off, sampling, and sparge valves). It is recommended that tanks and pipelines be labeled and kept out of public access areas. Loading/ unloading connections and pipelines should be capped or blank-flanged when they are not in service.

---

Spill Prevention Training [40 CFR 112.7(e)(10)]

---

A large number of spills is caused by operator error; therefore, training and briefings are important for the safe and proper functioning of a facility. Training encourages up-to-date planning for the control and response to a spill and an understanding of the facility's spill prevention controls and SPCC plan. Regular safety and spill prevention briefings should be held to facilitate discussions of spill events or failures, malfunctioning equipment, and recently developed precautionary measures. Also, one person must be designated accountable for spill prevention at the facility.

Owners and operators are responsible for properly instructing drivers, tank gaugers, pumpers, and any other operating personnel involved in oil operation systems in the operation and maintenance of equipment to prevent the discharge of oil and applicable pollution control laws, rules and regulations. All employees should be familiar with the SPCC plan and where it is kept, or have a copy of the plan available for their use.

Records of employee training and spill prevention briefings for personnel should be included in the SPCC plan and kept for a minimum of three years.

---

Troubleshooting

---

Facilities should consider current operations and how they can be improved to prevent spills and meet the regulatory requirements by conforming with good engineering practices. To this end, the questions and answers appearing below are based on practices observed at facilities by federal, state, and local regulatory agencies. Some of the issues and practices discussed are best management practices (BMPs) and may be supplemental to the regulatory requirements. Others may be essential to achieving compliance with the SPCC requirements or state regulations.

What types of procedures or equipment are in place at the facility to prevent and control a product discharge in the event of a human error or equipment malfunction?

Make sure that all valves are working properly. Shutoff valves that do not work properly may result in spills. These spills must be cleaned up by the attendants or drivers immediately and the valve must be repaired or replaced. Click here to get more information on Owner/Operator Relationships.

Spills should be cleaned up so that they are not collected in the oil-water separator. If a spill reaches an oil-water separator, it should be cleaned out immediately. Oil-water separators should have shutoff valves and must not automatically discharge treated water to a stormwater or sewer system or waterway without monitoring.

How is runoff (drainage) from vehicle and engine cleaning operations controlled?

Water from wash areas should be isolated from water in nonoperating areas, contained and treated on site or removed for offsite treatment to prevent a discharge of oil. Some facilities may use a system where water is recycled back to the wash area reducing the total amount of water used and reducing the potential for discharge of waste oils and other pollutants. These systems are usually equipped with oil-water separators. The oil-water separator system must be carefully monitored to prevent the accidental release of oil as a result of equipment failure.

How does the facility manage drainage of diked areas (or other water accumulation areas?)

Facilities must ensure that drainage valves are in the closed position. At the close of each business day and during and after storm events, facility personnel should double-check the position of the valves. Facilities must develop checklists and logs for noting the appearance of the water in diked areas. Checklists should note the time of valve opening and valve closing, and should be signed by trained, authorized personnel. Facility managers should make sure the checklists and logs have been adequately completed to evidence that all drainage procedures are properly followed.

If an overfill were to occur while filling an underground storage tank (UST), does the facility have response equipment in place to control the discharge?

The overflow protection equipment on USTs may only hold a small spill. Diversionary structures, such as curbing, must also be in place for UST filling areas. The containment areas must be capable of holding the contents of the largest single compartment of a tank car or truck that loads or unloads at the facility. Facilities should also have emergency response kits available nearby to contain any spills that occur.

The UST regulations found in 40 CFR part 280 have many requirements for overfill protection, such as in-line leak detection and automatic pump shutoff systems, which may be applicable to the facility.

What is the facility's protocol for maintaining the exteriors and interiors of aboveground storage tanks (ASTs) to prevent corrosion?

Facilities must follow good engineering practices to identify when it is appropriate and necessary to paint or coat ASTs and to retrofit tanks with liners. Internal corrosion, due to standing water inside the tank, is a contributing factor to tank failure. The water, being denser than the hydrocarbon product, collects in the bottom of the tank and corrodes the tank walls and bottom.

Are there visible oil stains in containment areas?

Oil leaks from tank seams, gaskets, rivets, and bolts must be cleaned immediately and the surfaces of containment areas should be kept clean. The leaking equipment should be repaired immediately. Washdown waters must be removed for proper disposal or treated prior to discharge to remove all oil contamination.

What is the facility's protocol for conducting integrity tests on tanks?

SPCC requires integrity testing, and each facility is responsible for determining which type of test is warranted based on good engineering practices and a regular schedule for these tests. To determine a schedule, the facility should consider the tank's age, location, and exposure. Tanks should also be integrity tested after earthquakes and major storms.

Is the facility located in a flood-prone area?

Tanks in flood-prone areas should be designed so that the lowest floor is elevated to or above the base flood level or be designed so that the structure below the base level is watertight with walls substantially impermeable to the passage of water, with structural components having the capability to resist effects of buoyancy.

How does the facility prevent pipeline ruptures?

Monitor pressure in piping systems, especially in the summer when temperatures may be high. Regulate pumping pressure so that the piping pressure does not exceed its pressure rating. Couplings and connections should have pressure ratings compatible with piping systems. Pressure-test piping before returning it to service and at regular intervals while in service.

How does the facility maintain flexible hosing?

Do not allow hosing to become twisted or kinked and avoid sharp bends. Be sure to stay within the manufacturer's recommended bend radius. Change flexible hosing when it is cracking or shows signs of excessive wear. Replace or repair connections and piping when leaks occur.

Are the loading/unloading procedures identified in the SPCC plan readily available and visible to all facility personnel and contractors involved in product transfer operations at the facility?

In addition to displaying procedures on signs, supervise transfer operations and ensure that drivers are knowledgeable in the correct use of equipment and critical oil spill response measures.

How are equipment leaks controlled and responded to at the loading/unloading racks and fuel dispensers?

When equipment, such as shutoff valves, does not function properly, repair it immediately. Clean up and contain spills quickly. Use catch buckets to control leakage from loading arms and terminal connections. To control leaks and spills from fuel dispensers, install catch pans with a leak-monitoring system.

How is the facility's equipment protected from vehicle impact?

All fuel tanks, pipelines, and dispensers should be protected by installing bumper poles and other physical barriers and warning signs, including signs identifying truck clearances.

How does the facility document spill prevention inspections?

Prepare facility-specific checklists for inspections of ASTs, valves, piping, pumps, dikes, oil-water separators, drainage sumps, monitoring devices, alarms, gauges, the truck loading/ unloading rack, and spill control equipment. Use these checklists during equipment inspections.

What is the facility's protocol for maintaining equipment and correcting visible oil leaks?

Institute a regular preventive maintenance program to prevent leaks, equipment malfunctions, and spills. Replace worn seals, fittings, and other parts before they leak or break. Wastewater or stormwater treatment system equipment, including oil-water separators, must be regularly maintained to prevent clogging and other problems that may lead to equipment failure.

Is the site adequately protected against vandalism?

Fences should completely enclose operating areas and be adequately designed to prevent passage (consider the height and durability of the fence). Consider installing motion detectors for activating lights at night. Make sure that all equipment that would permit the flow of product is adequately locked down.

Is the facility's training program adequate to maintain personnel awareness of the spill prevention techniques described in the SPCC plan and correct operating procedures?

Owners or operators are responsible for instructing their personnel in the operations and maintenance of equipment to prevent the discharges of oil and applicable pollution control laws, rules, and regulations.

Refresher training should be conducted at regular intervals. Training should include testing to ensure that personnel, especially new hires, have an understanding of the concepts discussed.

Is spill control equipment strategically located and is the storage area adequately stocked based on the facility's needs?

Keep spill kits containing absorbent pads, booms, disposal containers or bags, an emergency response guidebook, and a fire extinguisher in a cabinet or locker near the storage and loading/unloading areas. Regularly inspect the cabinet where emergency spill response supplies are kept to ensure the cabinet is properly stocked. For maintenance areas, a supply of granular absorbent should be readily available, possibly in a garbage can or 55-gallon drum in each maintenance bay.

Does the facility have a spill response plan?

For those facilities not required to prepare a facility response plan under 40 CFR part 112.20, it is still recommended to develop a spill response plan. Provide this plan to the fire department and local response agencies. Have frequent drills and invite local responders to participate.

---

Facility Construction and Design

---

There are a variety of ways for a facility to be designed and constructed to achieve compliance with the SPCC requirements. Facilities may differ greatly in the types of diversionary structures and spill control equipment employed. Small facilities may utilize simple yet effective methods while large facilities may employ state-of-the-art technologies to treat contaminated drainage, achieve overfill protection on tanks and tank trucks, conduct integrity testing, provide facility security, and train employees. Facilities should also consult industry associations, which specifically identify technical and engineering standards for the design and construction of tanks and pipelines; cathodic protection of tanks and pipelines; AST tank bottom liners; tank inspection, repair, alteration, and reconstruction; tank cleaning; and tank overfill protection. These standards may assist the facility in identifying good engineering practices and achieving compliance with the SPCC requirements.

Acknowledgements

We would like to acknowledge Bobbie Lively Diebold, U.S. EPA Headquarters and Dave Tordoff, U.S. EPA Region I for their valuable assistance in the preparation of this guide. The following publication also provided valuable assistance:

U.S. Environmental Protection Agency, 1995. SPCC/OPA Manual. U.S. EPA Region VIII, Ecosystem Protection and Remediation Preparedness Team. Denver, Colorado.

Local Navigation

• Region 6 Home
• Region 6 Superfund Program
• EPA Superfund Program
• About Superfund
• Superfund Frequently Asked Questions
• Human Health & Ecological Risk
• Laws, Policies & Guidance
• Information Sources
• Superfund en Español
• Regions & Partners
• Superfund for Kids!

• EPA Home
• Privacy and Security Notice
• Contact Us