Emergency Response
Shop Tour Stop #1

The following questions and guidance are taken from the
Consolidated Screening Checklist For Automotive Repair Facilities.

A “√” next to a response in the guide indicates that is the preferred response in terms of environmental compliance. If you select a response without a “√”, you may still be in compliance; however, you should verify that you are in compliance by contacting the appropriate federal or state regulatory agency and discussing your activity with them.

SPILL PREVENTION, CONTROL, AND COUNTERMEASURES (SPCC) AND EMERGENCY RESPONSE

In 1973, the Oil Pollution Act regulations were created to address the oil spill prevention provisions contained in the Clean Water Act of 1972. The regulation forms the basis of EPA’s oil spill prevention, control, and countermeasures (SPCC) program, which seeks to prevent oil spills from certain above ground storage tanks (ASTs) and underground storage tanks (USTs). In particular, the regulation applies to facilities that:
  • Have an aboveground storage capacity of more than 660 gallons in a single AST or more than 1,320 gallons in multiple ASTs, or a total underground storage capacity of 42,000 gallons; and
  • Has physical potential to discharge oil in harmful quantities into navigable waters of the United States.
On July 17, 2002, EPA issued updated SPCC program requirements. The capacity limits were amended to reduce the program coverage to smaller facilities. To be subject to the amended SPCC requirements, a facility must meet one of the following conditions:
  • Have an above ground storage capacity of 1,320 gallons or greater. To be counted in the 1,320 gallons, the oil must be in storage vessels or drums-55 gallons or larger. To be subject to this regulation, an automotive repair shop must store more than 24-55 gallon drums with oil on-site.
  • Have a completely buried underground storage capacity greater than 42,000 gallons and is not subject to either federal or state underground storage tank requirements.
Most automotive shops that dispense gasoline or keep used oil on their sites for energy recovery should benefit from this amended rule. Since the shop’s fuel tanks are buried underground, are subject to either the federal or state underground storage tank program and below the underground storage capacity of 42,000 gallon, most automotive shops that dispense fuel will not be subject to the SPCC program. Check www.epa.gov/oilspill/spccguid.htm for more information.

Does the facility’s storage tank capacity make it subject to the Oil Pollution regulations?

If the automotive shop stores oil that exceeds the regulatory capacity of 1,320 gallons or greater in aboveground storage vessels or has a completely buried underground storage capacity greater than 42,000 gallons and is not subject to either federal or state underground storage tank requirements, the shop needs to complete a SPCC plan.

Yes--Facility exceeds capacity limits indicated above.

No--Facility storage capacity is less than limits above.

N/A--Facility does not have storage tanks.

Could spilled oil reach waters of the United States or adjoining shorelines?

The determination is based solely on a consideration of geographic and location aspects of the facility. The location of the facility must be considered in relation to streams, ponds, ditches (perennial or intermittent), storm or sanitary sewers, wetlands, mudflats, sandflats or other waters of the United States. The distance to waters of the United States, volume of product stored, worse case weather conditions, drainage patterns, land contours, soil conditions, etc. must be taken into account. This determination may not include considerations of man-made features, such as, dikes, equipment of other structures that may hinder, restrain, contain or prevent an oil discharge.

Yes--The determination indicates a spill can reach waters of the United States or adjoining shorelines.

No--The determination indicates a spill can not reach waters of the United States or adjoining shorelines.

N/A--Facility does not have storage tanks.

NOTE: If you responded “Yes” to the two questions above, you must have a Spill Prevention, Control and Countermeasures Plan in place for your automotive shop.

Does the facility have a Spill Prevention, Control, and Countermeasures (SPCC) plan signed by a Professional Engineer?

The SPCC plan must be on-site if the facility is normally manned for at least eight hours per day. Otherwise, it must be kept at the nearest field office. An SPCC plan is a written description of how a facility’s operations comply with the prevention guidelines under the Oil Pollution Prevention regulation. Each SPCC plan, while unique to the facility it covers, must include certain elements to ensure compliance with the regulations. These elements include:
  • Written descriptions of any spills occurring within the past year, corrective actions taken, and plans for preventing their recurrence.
  • A prediction of the direction, rate of flow, and total quantity of oil that could be discharged where experience indicates a potential equipment failure.
  • A description of secondary containment and/or diversionary structures or equipment to prevent discharged oil from reaching navigable waters.
  • If containment and/or diversionary equipment or structures are not practical, a strong oil spill contingency plan and a written commitment of manpower, equipment, and materials to quickly control and remove spilled oil.
  • A complete discussion of the spill prevention and control measures applicable to the facility and/or its operations.
Facilities must have an SPCC plan that has been signed by a professional engineer. This is not the same as a “hazardous materials plan,” or an “emergency response plan.” However, some facilities may combine the SPCC plan with another plan. If this is done, the plan should include wording such as “spill control and emergency response plan.” For more information refer to EPA’s website at: www.epa.gov/oilspill/spcc.htm

Yes--The facility has an SPCC that has been signed by a professional engineer.  √

No--The facility does not have an SPCC plan, or the plan is not signed by a Professional Engineer.

N/A--The facility is not required to have an SPCC plan.

Is the phone number for the National Response Center posted onsite for immediate reporting of oil spills?

In addition to an SPCC plan, EPA requires that if a facility has an accidental release of an oil spill that meets federal reporting requirements (e.g., a discharge of oil that causes a discoloration or “sheen” on the surface of water, violates water quality standards, or causes a sludge or emulsion to be deposited beneath the surface or on adjoining shorelines), the oil spill must be reported to the National Response Center (NRC) at 1-800-424-8802.

Yes--NRC phone number is available on-site.  √

No--NRC phone number is not available.



Source: U.S. EPA Office of Enforcement and Compliance Assurance, EPA 305-B-03-004, October 2003.


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