Yes, you can write and even certify your Spill Prevention, Control and Countermeasures Plan (SPCC)—even if you are not licensed as a Professional Engineer (PE). And though you do not need to be certified in your facility’s state, you still need to keep in accordance with all state laws, naturally. However, as some states do not allow self-certification, you should consult with yours to ensure that Plan certification is not limited to PEs only.
Self-certification is mandatory for any “qualified facility”, that being one with:
- an aggregate storage capacity of 10,000 gallons or less
- no single discharge exceeding 1,000 gallons in the last three years
- no two single discharges greater than 42 gallons each in a one year period
However, if your facility does not meet such requirements, you should probably still write and certify a plan to help keep in compliance.
What Does Self-Certification Include?
An SPCC Plan stems from the rule that details all requirements for “oil spill prevention, preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines”. This EPA regulation applies to more than 630,000 companies.
As an owner/operator certifying a facility’s SPCC Plan, you must be familiar with the requirements of the 40 CFR part 112 of the Plan and have visited and examined the facility.
You need to also certify that:
- your Plan has been prepared in accordance with accepted and sound industry practices and standards and with the rule requirements
- procedures for required inspections andtesting have been established
- the Plan is being fully implemented
- your facility meets the qualifying criteria
- the Plan does not deviate from rule requirements (except as allowed and as certified by a PE)
- management approves the Plan and has committed resources to implement it
Bypassing the Plan
Now, if you have no individual above ground oil storage containers greater than 5,000 gallons and meet certain eligibility criteria for being a Tier 1 facility, you can just complete a self-certified SPCC Plan template in lieu of a full Plan.
A Tier I qualified facility must have:
- a total aboveground oil storage capacity of 10,000 U.S. gallons or less
- no aboveground oil storage containers with a capacity greater than 5,000 U.S. gallons (as mentioned before)
- no discharges to navigable waters or adjoining shorelines in the three years before the SPCC Plan is certified, as described below:
- a single discharge greater than 1,000 gallons, or
- two discharges of oil each greater than 42 gallons within any 12-month period.
(note: this does not include discharges that are the result of natural disasters, acts of war, or terrorism. Also, in determining applicability to this SPCC reporting requirement, the gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. EPA considers the entire volume of the discharge to be oil for the purposes of these reporting requirements.
Or, Maybe You Get PE-Certified?
As you can see, self-certification, while possible, is a robust task and must be done thoroughly and to exceedingly detailed standards. So, bringing a Professional Engineer on board would be a properly professional and sensible thing to do. More info on all this is available at the EPA.
Need someone to help make sure your company has and SPCC plan? We deal with these issues every day. Contact Us (859-689-9222) to get more information about how we can help your business.