CaseMark SPCC Plan Drafting
Generates a 40 CFR Part 112-compliant SPCC Plan for facilities storing oil in quantities that could discharge into navigable waters or adjoining shorelines.
Prerequisites
Gather before drafting:
- Facility tier — Tier I (qualified: ≤10,000 gal total, no single tank >5,000 gal, no discharge history in past 3 years), Tier II, or PE-certified
- Site documentation — coordinates, site plans, engineering drawings, topographic/drainage maps
- Oil storage inventory — tank types, capacities, oil types, ages, materials, locations
- Spill history — prior SPCC plans, inspection reports, discharge records
- Emergency contacts — facility coordinator, responders, cleanup contractors, NRC number
Quick Start
- Classify the facility tier and determine certification path (PE vs. self-certification)
- Build the oil storage inventory table from client data
- Calculate secondary containment volumes per the 110%/10% rule
- Draft the tiered spill response matrix
- Produce training schedule, inspection program, and recordkeeping plan
- Add certification/attestation block matching the facility tier
- Compile appendices (site maps, calculations, checklists, contact lists)
Plan Sections
1. Introduction & Regulatory Basis
Table with: facility name/owner/operator/address/coordinates, regulatory basis (40 CFR Part 112; CWA §311), facility tier with justification, and plan objectives.
2. Facility Characterization
Document coordinates, proximity to navigable waters, topography, drainage patterns, all discharge pathways (storm drains, ditches, culverts, overland flow), seasonal variations. Reference uploaded site maps.
3. Oil Storage & Equipment Inventory
Tabulate each container: type (AST/UST/mobile/drum/IBC), oil type and characteristics, max and typical capacity (gal), construction material, age/condition, location keyed to site map. Include aggregate and individual capacities per 40 CFR 112.7.
4. Spill Prevention & Containment
Secondary containment rule: each area must hold the greater of 110% of largest single tank OR 10% of total aggregate capacity. Show volume calculations.
Document per storage area:
- Containment type (berms, dikes, curbing, lined areas)
- Overfill prevention (high-level alarms, automatic shutoffs)
- Transfer operation controls
- Drainage controls (valves, diversion systems)
- Security measures (fencing, locks, lighting)
- Inspection procedures and maintenance program
Cite 40 CFR 112.7 and 112.8–112.12 as applicable. [VERIFY] citations against current eCFR.
5. Tiered Response Matrix
| Spill Size | Immediate Action | Containment | Notification |
|---|---|---|---|
| Minor (<25 gal) | Deploy absorbents | On-site | Internal log only |
| Moderate (25–250 gal) | Emergency shutdown | Activate drainage controls | Facility coordinator + state |
| Major (>250 gal or reaches water) | Full shutdown | Deploy booms/barriers | NRC (800-424-8802) + state + local |
Include decision flowchart based on spill location and pathway to water.
6. Emergency Response Organization
Provide org chart: SPCC Coordinator → Operations Lead, Environmental Lead, Safety Officer, plus external resources (cleanup contractor, fire dept, state agency, NRC 800-424-8802). Document notification timing and content per 40 CFR 112.4.
7. Training & Inspection Program
Training: New hires get full SPCC orientation before oil-handling duties. Oil handlers: annual spill response/transfer training. All personnel: annual plan awareness. Document attendance and competency.
Inspections: ASTs/containment monthly (visual + checklist). Transfer equipment before each use. Piping/valves monthly visual, annual integrity. Spill response equipment quarterly. Security systems monthly.
8. Recordkeeping & Plan Maintenance
| Record | Retention |
|---|---|
| Inspection/training logs | 3 years min |
| Spill reports | 5 years |
| Plan amendments | Life of plan |
- Full plan review every 5 years (40 CFR 112.5(b))
- Amend within 6 months of material changes (new tanks, modifications, spill events)
- PE re-certification required for technical amendments at PE-certified facilities
9. Certification & Attestation
PE-certified facilities (40 CFR 112.3(d)): Include PE certification block with name, registration number, state, signature, date, and seal — attesting plan prepared per good engineering practice and 40 CFR Part 112.
Qualified facilities — self-certification (40 CFR 112.6(a)(2)): Include owner/operator attestation block with name, title, signature, date — certifying familiarity with 40 CFR Part 112 and facility examination.
10. Appendices
A: Site map (tanks, drainage, containment) | B: Topography/drainage to navigable waters | C: Equipment specs | D: Containment volume calculations | E: Emergency contacts | F: Blank inspection checklists | G: Training materials/sign-offs | H: Spill history log
Pitfalls & Checks
- [VERIFY] all 40 CFR Part 112 citations against current eCFR before finalizing
- Animal fats and vegetable oils are covered under 40 CFR 112 — do not exclude non-petroleum oils
- UST/buried storage must address 40 CFR 112.8–112.12 tank-specific requirements
- State/local requirements may exceed federal SPCC — flag where state law should be checked
- Plan must be maintained on-site (or nearest field office) and available during inspections
- Never fabricate facility-specific data; use
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