How do I build a Spill Prevention, Control, and Countermeasure (SPCC) Plan?

A Spill Prevention, Control, and Countermeasure (SPCC) plan is an EPA-required written policy for facility owners that hold oil/petroleum-based substances in either aboveground storage tanks (ASTs) or underground storage tanks (USTs).

Dealers often have both aboveground and underground storage tanks that store gasoline, new or used oil, antifreeze, etc. The main purpose of the policy is to:

  • inventory all tanks at the facility,
  • designate employees and emergency contacts that will be instrumental should there be a spill, and
  • outline policies and procedures for spill prevention.

👍 There are complex rules in place to determine whether a dealer must build an SPCC plan that is based on tank quantities at the facility, but there’s no need to worry because ComplyAuto has automated most of this process!

Step-by-Step Instructions for creating an SPCC Plan: 

  • Log into the ComplyAuto Safety portal.

📓 Before you begin: You’ll first need to ensure that you’ve added all of the facility’s storage tanks to the Equipment Checklists tab within the dashboard prior to building an SPCC plan.

  • Click here to view our article on how to add storage tanks and other equipment to the Equipment Checklists tab.

 

  • Once all of your storage tanks have been added, click on “Policies” on the left hand menu. You will be redirected to the ComplyAuto Workforce dashboard.

 

 

 

  • Click on the “Environmental Health & Safety” tab, scroll down



  • Click the “View or Create Policies” button next to Spill Prevention, Control, and Countermeasure Plan.

  • Click the “Create New Policy” button in the top right corner. 

📓  You can add an existing SPCC plan by clicking the button directly to the left titled “Add Existing Policy.” 

Let's explain each piece of the form you're about to fill out:

General Info:

  •  Enter the desired Program Name, select which locations the policy will apply to, then click the “Next” button on the bottom right. 

💡The EPA gives deference to facility owners of multiple worksites to determine whether they fall under the same corporate umbrella. Most ComplyAuto dealerships with multiple locations typically build one SPCC plan that includes all of their facilities.

Eligibility:

  •  Our program builder will automatically calculate your tank capacity totals and determine whether you are eligible to build an SPCC plan within the ComplyAuto dashboard. You will also see your tank totals along with an option to update your storage tanks if the totals seem inaccurate. 
💡 There are various types of SPCC plans, each with their own eligibility requirements. ComplyAuto currently supports building a Tier I or self-certified plan.

Recent Spills:

  • Click “Yes” or “No” as to whether your facility has had a single oil spill or discharge greater than 1,000 gallons or two spills or discharges greater than 42 gallons within any 12-month period to navigable waters or adjoining shorelines in the prior three years.
Program Administrator:
  • Enter the employee name, title, and email of the person(s) at your facility that will be in charge of administering the SPCC plan. 
Facility Information:
  • Enter the facility name, address, and telephone number. 
Self-Certification Information:
  • Enter the employee that will be responsible for self-certifying the program.
    • This can be done by either searching for an existing employee using the search bar, or by clicking “Add New Employee” by which you will enter their name, email address, and job title.
    • Once the plan is built, this employee will receive a notification email with instructions on how to certify the plan. 
Storage Tank Information:
  • Part of creating an SPCC requires that you document the potential failures, direction of flow, secondary containment methods, secondary containment capacities, and the description and location of each tank. Do this by clicking the drop-down arrow next to each tank listed and complete each required field for each tank listed. 

💡 You’ll want the person most knowledgeable about your facility’s storage tanks completing this section.

      Discharge Prevention Manager
  • Enter the name of the individual that will be listed as the Discharge Prevention Manager. This person’s responsibility will be discharge prevention and response.
Emergency Contact List 
  • Enter the organization/person name and telephone number for contacts you’d like to add to the Emergency Contact List within your SPCC plan.

💡 Some examples of organizations you might want to include would be state or local authorities that must be notified by law, cleanup contractors, dealership personnel tasked with spill prevention and management, local fire departments, local police departments, and nearby hospitals.

Facility Diagrams
  • Upload your facility diagrams that will be attached to your SPCC plan.
    • Click the “Finish” button to complete the SPCC building process.

 

💡Tip: The EPA provides guidance on building a facility diagram for an SPCC here.  


Ensure that the person responsible for self-certifying the SPCC plan does so as soon as possible, otherwise the plan will not contain the required self-certification section for it to be considered complete and compliant with the SPCC rule.