Quality and Consistency Review of SPCC and FRP Plans: Summary of Findings
Environmental Protection Agency - Office of Emergency Management
Review Objectives and Methodology
The Environmental Protection Agency (EPA) conducted an internal quality and consistency review of a sample of Spill
Prevention, Control, and Countermeasure (SPCC) Plans and Facility Response Plans (FRPs) required under 40 CFR part
112. The review was to inform the Agency's continued outreach to provide regulatory clarity and improve SPCC and FRP
compliance.1
EPA Headquarters staff surveyed regional offices for data related to SPCC Plans and FRPs reviewed during routine
compliance monitoring activities for Fiscal Years 2018 and 2019. The selected sample included a diverse distribution of
industry sectors. Further, where possible, the sample included facilities subject to both SPCC and FRP requirements,
generally resulting in a selection of facilities with larger oil storage capacities. Only facilities with identified Plan
deficiencies were reviewed in order to assess Plan inconsistencies with the applicable rule requirements. While the
compiled data from the review reflect overall SPCC and FRP compliance, this factsheet focuses only on identified SPCC
Plan and FRP deficiencies and the data below highlight the number of unique facilities with at least one deficiency in any
given SPCC or FRP requirement area. The Agency commits to work with SPCC/FRP facilities to bring them into
compliance or will take action, where appropriate.
Selected SPCC and FRP Facilities
EPA reviewed inspection data for 120 SPCC-regulated facilities and
55 FRP-facilities (Figure 1 presents the distribution of facilities by
sector). The aggregate oil storage capacities of reviewed facilities
range between 4,000 gallons to more than 857 million gallons. The
largest facilities in terms of oil storage capacity were oil refineries,
military installations, and bulk storage terminals. FRP facilities,
almost half of which were bulk storage facilities and terminals for
this review, are among the largest facilities covered under 40 CFR
part 112. The reviewed FRP facilities have an average aggregate oil
storage capacity of 45 million gallons of oil (69,000 to 857 million
gallons) and have estimated worst case discharge planning volumes
averaging more than 3 million gallons (94,000 to 20 million gallons).
SPCC Plan Deficiencies
Of the 120 SPCC-regulated facilities reviewed in this study, EPA
identified that 8% (10 facilities) did not have an SPCC Plan at the
time of inspection. Of the 110 facilities that had an SPCC Plan, EPA
identified an average of four Plan deficiencies at each SPCC facility
reviewed. As shown in Figure 2, the five most common types of
SPCC Plan deficiencies were on provisions for Plan content, general
secondary containment, integrity testing, sized secondary containment, and drainage.
EPA noted numerous SPCC Plans with the following deficiencies: inadequate or no documentation of the Plan review
and evaluation every five years; Plans not amended by facility owners or operators when required; omission of key
information from the facility diagram; failure to address required containment for piping; failure to address integrity
testing of bulk storage containers; failure to demonstrate that secondary containment met the requisite size or design
requirements; or failure to provide procedures for controlling stormwater discharges from diked areas. Within the
Figure 1: Reviewed SPCC and FRP facilities by
sector
Number of Facilities
0 10 20 30 40 50 60
Bulk storage/terminal
Oil production
Power generation
Refinery
Military/national security
f2]
AFVO processing
Ti4
Manufacturing
i
Airport
l3
Other retail/commercial
I3
Asphalt Plant
L
Marina
1 2
0
Biodiesel production
0
1 1
Fish processing
1 1
0
POTW
1 1
0
Rail yard
\i
Used oil processor
h
i SPCC bFRP
1 The review also follows recommendations by the Office of Inspector General (OIG) in "EPA Needs to Further Improve How It
Manages Its Oil Pollution Prevention Program" (Report No. 12-P-0253) February 6, 2012.
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facilities reviewed, there were no noticeable differences in the types of Plan deficiencies that could be attributed to
industry type or differences in oil storage capacities.
Figure 2: FY18 & FY19 SPCC Plan deficiencies among the 120 SPCC facilities reviewed for this study.
Top Deficiency Category Relevant SPCC Provision(s)
Plan content, certification, 112.3 Plan Requirements
and reviews 112.3(e) Plan Availability
112.5(a) Plan Amendments
112.5(b) 5-Year Review
112.7(a) Plan Content
112.7(j) Other Applicable Regs
Containment (general) 112.7(c) General Containment
Testing and inspection: 112.8(c)(6) Integrity
integrity testing Testing/Inspections
112.12(c)(6) Integrity Testing
Containment (sized) 112.8(c)(2) Bulk Storage Sized
Secondary Containment
112.9(c)(2) Bulk Storage Sized
Secondary Containment
112.12(c)(2) Bulk Storage
Sized Secondary Containment
Drainage 112.8(b) Facility Drainage
112.8(c)(3) Diked Drainage
112.8(c)(9) Effluent Treatment
Piping: General 112.8(d) Transfer
Operations/Piping
Piping: Inspections 112.8(d) Piping Inspections
112.9(d) Piping Inspections
Discharge prediction 112.7(b) Discharge Prediction
PE certification 112.3(d) PE Certification
EPA identified an average of four Plan deficiencies per FRP facility Fjgure 3; FYlg & Fyig FRp defjciencie5 among the
reviewed. The five most common types of FRP deficiencies were 55 FRp facilities reviewed for this study
on provisions for diagrams (i.e., site plan, evacuation plan,
drainage); discharge scenarios (including worst-case discharge);
vulnerability analysis; hazard evaluation {i.e., spill history,
analysis of discharge potential); and plan implementation (i.e.,
description of containment and drainage planning, disposal plans,
and response resources).
Numerous FRP facilities also lacked details about their response
equipment, omitted key information from their emergency
response action plan (ERAP), did not conduct required
preparedness drills and exercises, and failed to train their
personnel on appropriate oil spill response measures.
Limitations
This qualitative analysis provides a snapshot of oil inspections in
two Fiscal Years (2018 and 2019). While illustrative of the
diversity of sectors, facility types, and operating conditions, the
sampled facilities reflect only a small portion of the universe of
facilities regulated under 40 CFR part 112. The frequency of deficiencies in this sample is not indicative of overall
compliance with SPCC and FRP requirements.
Number of Facilities with SPCC Plan Deficiency in Category
(
) 20 40 60 80 100 120
Plan content, certification, and reviews
119
Containment: General
43
Testing and inspection: Integrity testing
38
Containment: Bulk Storage Container (Sized)
¦ 33
Drainage
33
Piping: General
29
Piping: Inspections
¦ 23
Discharge prediction
| 20
PE certification
19
Containment: Mobile/Portable Container
18
Testing and inspection: Records
18
Bulk containers: General
1 ]
L5
112.7 General Requirements
L5
Other containers
11:
3
Deviations: Impracticability
¦ 1:
3
Testing and inspection: Brittle fracture
¦ 1;
>
Training
¦ 11
Deviations: EE
¦ 10
Loading/unloading racks: Containment
¦ 10
Loading/unloading racks: General
¦ 9
Bulk containers: Discharge
¦
PE certification of technical amendments
¦
Applicability and harm determination
¦ 7
Overfill
¦ 6
Security
|4
Contingency Plan
1 2
Discharge notification
1 1
Miscellaneous other provisions
U
FRP Deficiencies
Number of Facilities with FRP Deficiency in
Category
0 5 10 15 20 25 30 35
1.9 Diagrams
1.5 Discharge Scenarios
¦ 27
1.4.2 Vulnerability Analysis
24
1.4 Hazard Evaluation
¦ 23
1.7 Plan Implementation
¦ 22
[
1.3.2/1.3.3 Response Equipment
| 21
1.1 ERAP
20
1.8 Drills/Exercises, Training
¦ 18
1.3.4 Response Personnel
| 17
1.2 Facility Info
15
1.3 Emergency Response
15
2.0 Certification and Cover Sheet
15
1.3.5 Evacuation Plan
¦ 12
1.3.1 Spill Notification
| 8
1.6 Discharge Detection
1 6
1.3.6 Ql
I 2
Miscellaneous Other Provisions
¦ 2
Plan Updates
¦ 2
1.10 Security
1 1
Plan Format (General)
1 1
2
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