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...for Onshore Oil Production, 

Drilling and Workover Facilities

Click to add your information here

SPCC 101...
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Please note that this presentation 

is a summary and does not cover 

every SPCC provision. 

Always refer to the SPCC rule and official 

Agency guidance found at 

www.epa.gov/oilspill
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What is the SPCC Rule?

 Spill Prevention, Control, and Countermeasure 

rule

 Part of the Oil Pollution Prevention regulation 

(40 CFR part 112) 

– Includes requirements for Facility Response Plans 

(FRPs) for certain facilities which may pose a substantial 

harm to waterways and the environment

 Purpose – To develop plans designed to prevent oil 

discharges from reaching the navigable waters of 

the U.S. or adjoining shorelines
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Requirements of the SPCC rule

 Requires certain facilities, including production 

facilities, to develop and implement a sitespecific SPCC Plan to address:

– Containment and procedures to Prevent oil 

discharges;

– Proactive Control measures to keep an oil discharge 

from entering navigable waters of the U.S. or 

adjoining shorelines (containment); and

– Effective Countermeasures to contain, clean up, and 

mitigate any oil discharge that affects navigable 

waters of the U.S. or adjoining shorelines (spill 

response measures). 
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SPCC Rule Overview

 Authority from Clean Water Act

 Oil Pollution Prevention regulation 

codified at 40 CFR part 112

 Original rule effective in January 1974

 Non-delegable to other agencies
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Rule Applies To NonTransportation Related Facilities

 Drilling

 Producing

 Gathering

 Storing

 Processing

 Refining

 Transferring

 Distributing

 Using

 Consuming

Regulations apply to owners and operators 

of facilities involved in:
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What are the SPCC criteria?

 Facility stores > 1,320

gallons of oil in aggregate 

above-ground storage or 

has 42,000 gallons of 

completely buried oil 

storage capacity; and

 Facility has a “reasonable 

expectation of an oil 

discharge” to waterway or 

adjoining shoreline.

You must have an SPCC Plan if:
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SPCC Applicability

 Owner/operator makes the initial decision on 

applicability of SPCC regulations to the facility

– Does the facility meet the applicability criteria 

(volumes of oil, expectation to spill to waterway)?

 No requirement to submit SPCC Plan to EPA 

for approval

 EPA does not formally “approve” or disapprove 

of SPCC Plan

 Plan is required upon inspection during regular 

workday
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SPCC Applicability

Counted Not Counted

55-gallons or greater 

5-gallon container 30-gallon drum

Permanently Closed
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Definitions - Oil

 Oil, as defined in Section 311 

(a)(1) of the CWA, can be of 

any kind or in any form 

including, but not limited to

- Petroleum and nonpetroleum based oils

- Crude Oil

- Refined Products

- Animal Fats, and 

- Vegetable oils
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Examples of Oil at Production, 

Drilling and Workover

 Produced water containing oil 

 Crude oil

 Oily waste

 Fuel for drill rig 

 Hydraulic oils
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Examples of Oil at Production, 

Drilling and Workover

 Fuel storage for vehicles

 Lubrication oils 

(pumpjack)

 Oil in transformers

 Liquid oil condensate

 Oil based frac fluids

 Natural Gasoline


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Navigable Waterways of the U.S. 

and Adjoining Shorelines

 Applicability of the SPCC rule is predicated on a reasonable 

expectation of discharge of oil to “navigable waters of the U.S. or 

adjoining shorelines”

 What are navigable waters of the U.S.? In general:

– Surface waterways – streams, creeks, rivers, lakes

– Wetlands adjacent to a navigable waterway

 Nexus important

– Can be intermittent streams. Best determination if flowing at least 

seasonally (3 months or more), depending on several factors (see 

Rapanos Guidance)

http://www.epa.gov/owow_keep/wetlands/guidance/CWAwaters.html

– Defined flow pathway to clearly navigable waters of the U.S. good 

start in determination – don’t assume

 EPA has developed draft guidance on navigable waters of the U.S 

and adjoining shorelines.

http://water.epa.gov/lawsregs/guidance/wetlands/CWAwaters.cfm
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Navigable Waters of the U.S. and 

Adjoining Shorelines Discussion
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What is a “Reasonable 

Expectation of an Oil Discharge”?

 Initial determination by the owner/operator based on 

geographical and location aspects of the production 

facility

 You may consider proximity to water, land contour, 

drainage

 Exclude manmade features, such as secondary 

containment dikes around tanks and impoundments, 

in determination

 Good idea to document determination

- Particularly if you conclude you are not subject to the rule

- Not a rule requirement

 See Section 2.4 of SPCC guidance document

http://www.epa.gov/emergencies/docs/oil/spcc/guidance/2_Applicability.pdf
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Definition of Production Facility

 Revision clarifies that the 

definition of “production facility” 

is used to determine which 

sections of the rule apply at a 

particular facility (e.g., §112.9).

 Revised definition is consistent 

with the revision to the 

definition of “facility”.

 Clarifies the flexibility allowed in 

determining the boundaries of 

the facility.

 Clarifies that condensate is 

regulated. §112.2
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What the definition means...

 According to EPA guidance, 

the extent of a “facility” 

depends on site-specific 

circumstances:

- Ownership, management, and 

operation of the buildings, 

structures, equipment, 

installations, pipes, or pipelines 

on the site;

- Similarity in functions, 

operational characteristics, and 

types of activities occurring at 

the site;

- Adjacency; or

- Shared drainage pathways (e.g., same receiving water bodies).
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Amended Definition

Production facility means all structures 

(including but not limited to wells, 

platforms, or storage facilities), piping 

(including but not limited to flowlines or 

intra-facility gathering lines), or 

equipment (including but not limited to 

workover equipment, separation 

equipment, or auxiliary non-

transportation-related equipment) used 

in the production, extraction, recovery, 

lifting, stabilization, separation or treating 

of oil (including condensate), or 

associated storage or measurement, and 

is located in an oil or gas field, at a 

facility. This definition governs whether 

such structures, piping, or equipment are 

subject to a specific section of this part.
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Onshore Drilling and 

Workover Requirements 
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Onshore Drilling and Workover 

Requirements 

 Meet general 

requirements listed 

under 40 CFR 112.7, 

and:

 Position or locate 

mobile drilling or 

workover equipment so 

as to prevent a 

discharge 

112.10(b)
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 Provide catchment basins, reserve pits, or 

diversion structures to contain any spill of oil 

or oily fluids (drilling mud)

Onshore Drilling and Workover 

Requirements 

112.10(c)
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 No specific sizing 

requirement, and no 

freeboard requirement 

for secondary 

containment

112.10(c)

Onshore Drilling and Workover
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 Install a Blow Out 

Prevention (BOP) 

assembly and well 

control system

 The BOP assembly and 

well control system 

must be capable of 

controlling any wellhead pressure that may 

be encountered

Onshore Drilling and Workover

112.10(d)
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“Wet Gas” and “Dry Gas” Facilities

 Liquid condensate is an oil. 

 A natural gas production facility may store 

condensate in quantities that meet the applicability 

criteria for the SPCC. 

– Considered a production facility (§112.9 applies). 

– Called a “wet gas production facility”

 EPA believes that a “dry gas production facility” is 

not an oil production, oil recovery, or oil recycling 

facility, as described in the clarification published 

May 25, 2004 (69 FR 29728)

– Stores no condensate

– SPCC requirements do not apply, so long as no other oil is 

stored at the facility to make it otherwise regulated 
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Dry Gas and Produced Water Tank
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Produced Water Container

 Produced water container means 

a storage container at an oil 

production facility used to store 

the produced water after initial 

oil/water separation, and prior to 

reinjection, beneficial reuse, 

discharge, or transfer for 

disposal

 Definition is used to determine 

which containers are eligible for 

alternative measures for 

produced water containers
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Produced Water Container
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Produced Water Containers

Above left: Infrared photograph of a produced water 

storage tank with a two foot oil layer on top of water.
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Permanently Closed  Permanently closed means any container or facility for which: – All liquid and sludge has been removed from each container and 

connecting line; 

– All connecting lines and piping have been disconnected from the 

container and blanked off; 

– All valves (except for ventilation valves) have been closed and 

locked; and 

– Conspicuous signs have been posted on each container stating 

that it is permanently closed and 

noting the date of closure.
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Permanently Closed

 SPCC rule exempts any oil storage container that is 

permanently closed.

– A tank that has either never stored oil, or has been 

permanently closed, and arrives at a facility is not 

counted until the tank is actually used to store oil.

 Definition of “permanently closed” does not require 

a container to be removed from a facility.

– Permanently closed containers may be brought back 

into use as needed for variations in production rates 

and economic conditions.
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Key SPCC Requirements

 Prepare Plan in accordance with Good 

Engineering Practices

 Full approval of management to 

implement Plan and sign off

 Follow sequence of Section 112.7, or use 

a cross-reference section
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Key SPCC Requirements

 SPCC regulations requires preparation and 

implementation of a written Plan to address:

– Operating procedures for routine handling of 

products to prevent a discharge of oil;

– Discharge or drainage control measures to 

prevent a discharge of oil;

– Countermeasures to contain, clean up, and 

mitigate an oil spill;

– Methods of disposal of recovered materials; and

– Contact list and phone numbers of company, 

contract response personnel, and National 

Response Center
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Professional Engineer (PE)

 Certified by a licensed PE, and attests:

– PE familiar with 40 CFR Part 112

– PE or agent visited facility

– In accordance with good engineering practices

 Consider applicable industry standards

 In compliance with regulations

– Inspection and testing procedures 

are established
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Professional Engineer (PE)

 Certified by a licensed PE, and attests:

– Plan is adequate for facility

– That, if applicable, for a produced water container 

subject to §112.9(c)(6), any procedure to 

minimize the amount of free-phase oil is designed:

• To to reduce the accumulation of free-phase oil; and 

• Procedures and frequency for required inspections, 

maintenance and testing have been established and are 

described in the Plan
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 SPCC Plan must be maintained at facility if 

manned 4 hours/per day or more, or at nearest 

field office if manned less than 4 hours/per day 

 Usual and customary business practices records 

serve as documentation of inspection or tests

Key SPCC Requirements
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Inspections, Tests, and Records

 Conduct inspections and tests in accordance 

with written procedures developed by the 

facility or by the engineer who certifies the 

facility Plan

 Keep these written procedures and a record of 

the inspections and tests, signed by the 

appropriate supervisor or inspector, with the 

SPCC Plan for a period of three years
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General Secondary Containment

 “General” Secondary Containment requirement 

applies to the following examples:

– Christmas tree, wellhead, and stuffing box

– Oil-filled equipment (transformers, pumpjacks, etc.)

– Transfer areas

 Piping runs/racks, manifolds, etc.

 Flow and intra facility gathering lines

 Truck loading/unloading areas (not loading rack)

 No specific-sized volume requirement

 Sizing based on typical spill size not container size
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Specific Secondary Containment 

Requirements for Production

 Applies to bulk storage 

containers at the tank battery, 

separation and treatment 

facilities, including, but not 

limited to:

 Stock tanks, 

 Produced water containers,*

 Separation equipment*

(e.g., heater-treaters and 

separators)

 If facility drainage is used as 

secondary containment for 

bulk storage containers, then 

drainage from undiked areas 

must be safely confined in a 

catchment basin or holding 

ponds

 Secondary containment sized to the capacity of the 

largest single container with sufficient freeboard to 

contain precipitation

* The SPCC rule includes alternative measures for certain 

production equipment in lieu of sized secondary containment
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General Requirements Applicable 

to ALL Facilities

 Production facilities must meet general 

requirements under 112.7

– Except the security requirement ( 112.7(g))

– Except general containment requirement (§112.7(c)) for 

certain flowlines and gathering lines
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Production Facility Drainage 

 Oil field drainage

– Inspect at regularly 

scheduled intervals for 

an accumulation of oil 

that may have resulted 

from any small 

discharge

– Promptly remove any 

accumulations of oil

 Remove accumulated oil on the rainwater 

and return it to storage or dispose of it in 

legally approved method
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Container 

compatibility 

( 112.9(c)(1)):

Do not use a container 

for the storage of oil 

unless its material and 

construction are 

compatible with the 

material stored and the 

conditions of storage

Bulk Storage Containers 

at Production Facilities
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 For all bulk containers in the tank battery, separation and 

treatment facilities satisfy the sized containment 

requirement (sized to largest container plus freeboard for 

precipitation); or 

 For process vessel and/or produced water containers, you 

may meet the alternative compliance requirements

 For oil containers that directly support production 

operations at a production facility but are not a part of a 

tank battery, or separation, and treatment equipment, 

then follow §112.7(c) for secondary containment 

requirements

 If the bulk container does not support production 

operations then the §112.8 requirements apply

Bulk Storage Containers 

at Production Facilities 112.9(c)(2)
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Bulk Storage Container Inspections 

at Production Facilities

 Visual Inspection ( 112.9(c)(3))

 Periodically and upon a regular schedule visually 

inspect each container for deterioration and 

maintenance needs

 Include the foundation and support of each 

container that is on or above the surface of the 

ground
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Compliance Alternative: 

Produced Water Containers

 Instead of providing sized secondary containment for produced 

water containers, a facility owner/operator can: 

– Have a PE certify a procedure for each produced water container 

that is designed to separate the free-phase oil that accumulates on 

the surface of the produced water, that is implemented on a regular 

schedule; 

– Conduct visual inspections, maintenance and corrective action; 

 General secondary containment requirements still apply

If the facility discharges to navigable waters or adjoining shorelines:

– 1,000 U.S. gallons of oil in a single discharge, or

– 42 U.S. gallons of oil in each of two discharges within a 12 month period

from a produced water container, then the facility owner/operator may no longer 

take advantage of this alternative option and must comply with the sized secondary 

containment requirements at §112.9(c)(2) and inspection requirements at 

§112.9(c)(3) within six months of the discharge.
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 A procedure designed to remove free-phase oil that 

accumulates on the surface of the produced water 

container

– Implemented on a regular schedule

– General secondary containment must be able to address the 

amount of oil in the produced water container

 SPCC Plan must include:

– Description of the free-phase oil separation and removal;

– Frequency it is implemented;

– Amount of free-phase oil expected to be inside the container; 

and

– Description of the general secondary containment

 Owner or operator must keep records of the 

implementation of these procedures in accordance with 

§112.7(e). 

Procedure to Remove Oil from 

Produced Water Containers
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PE Certification

 PE attests that Plan is prepared in accordance 

with good engineering practices and includes a 

provision certifying that:

– An oil removal procedure for produced water 

containers is designed to reduce the accumulation 

of free-phase oil, and

– The procedures and frequency for required 

inspections, maintenance and testing have been 

established and are described in the Plan.
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Reporting of Oil Spills

 Report all oil discharges to navigable waters of the U.S. or 

adjoining shorelines to NRC at 1-800-424-8802

 Federal government's centralized reporting center, which 

is staffed 24 hours a day by U.S. Coast Guard personnel

 Any person in charge of a vessel or an onshore or offshore 

facility must notify NRC immediately after he or she has 

knowledge of the discharge

 NRC relays information to EPA or U.S. Coast Guard 

depending on the location of the incident

 An On-Scene Coordinator evaluates the situation and 

decides if federal emergency response action is necessary
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Specific SPCC Spill Reporting 

Requirements

 Report to the EPA Regional Administrator (RA) when 

there is a discharge of:

– More than 1,000 U.S. gallons of oil in a single discharge 

to navigable waters of the U.S. or adjoining shorelines

– More than 42 U.S. gallons of oil in each of two discharges 

to navigable waters of the U.S. or adjoining shorelines 

within a 12-month period

– When making this determination it is the amount of the 

discharge in gallons that reaches navigable waters of the 

U.S. or adjoining shorelines

– An owner/operator must report the discharge(s) to the 

EPA Regional Administrator within 60 days
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For More Information

 EPA’s SPCC web page

 http://www.epa.gov/emergencies/content/spcc/index.htm

 EPA Oil Spill and Emergency Management web pages

 www.epa.gov/oilspill

 www.epa.gov/emergencies

 HOTLINE: Superfund, TRI, EPCRA, RMP, and Oil 

Information Center

– (800) 424-9346 or (703) 412-9810

– TDD (800) 553-7672 or (703) 412-3323

– www.epa.gov/superfund/resources/infocenter 
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SPCC Contacts

REGION SPCC COORDINATORS

1

CT, RI, MA, NH, VT, ME

Alex Sherrin (617) 918-1252

sherrin.alex@epa.gov

2

NJ, NY, PR, VI

Larry D’Andrea (732) 906-6964

dandrea.larry@epa.gov

3

PA, WV, VA, MD, DC

Arlin Galarza-Hernandez (215) 814-3223

galarza-hernandez.arlin@epa.gov

4

KY, NC, TN, SC, MS, AL, GA, FL

Ted Walden (404) 562-8752

walden.ted@epa.gov

5

MN, WI, MI, IL, IN, OH

Barbara Carr (312) 886-7187

carr.barbara@epa.gov

6

NM, TX, OK, AR, LA

Don Smith (214) 665-6489

smith.donaldp@epa.gov

Chris Perry (214) 665-6702

perry.chris@epa.gov

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NE, KS, IA, MO

Alan Hancock (913) 551-7647

hancock.alan@epa.gov
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SPCC Contacts

REGION SPCC COORDINATORS

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MT, ND, SD, WY, UT, CO

Melissa Payan (303) 312-6511

payan.melissa@epa.gov

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CA, NV, AZ, HI, Guam, American 

Samoa, Northern Marina Islands

Pete Reich (415) 972-3052

reich.peter@epa.gov

Janice Witul (415) 972-3089

witul.janice@epa.gov

10

WA, OR, ID, AK

WA: Mike Sibley (206) 553-1886

sibley.michael@epa.gov

OR, ID: Richard Franklin (503) 326-2917

franklin.richard@epa.gov

AK: Matt Carr (907) 271-3616

carr.matthew@epa.gov

HQ- Office of Emergency 

Management:

Mark Howard (202) 564-1964

howard.markw@epa.gov

Patricia Gioffre (202) 564-1972

gioffre.patricia@epa.gov

Troy Swackhammer (202) 564-1966

swackhammer.j-troy@epa.gov

HQ- Office of Civil Enforcement:

David Drelich (202) 564-2949

drelich.david@epa.gov

Kelly Brantner (202) 564-9933

brantner.kelly@epa.gov

HQ- Office of Compliance: Dan Chadwick (202) 564-7054

chadwick.dan@epa.gov
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Legal disclaimer

• EPA has made every effort to ensure the 

accuracy of this presentation. However, please 

note: 

• This presentation is for informational purposes 

only and does not constitute Agency guidance.

• This presentation does not bind the Agency and 

does not govern Agency actions in the event of 

any conflict with a statute, regulation, policy, 

guidance, or other interpretation of the law by 

EPA.
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Questions?