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An SPCC is an EPA mandated Spill Prevention Containment and Countermeasure Plan under the Clean Water Act that all facilities (and drilling rigs*) must have that store more that 31 BBLS or  1,320 gallons of fluids on site such as crude oil, vegetable oil, gasoline, diesel, etc. (Drilling rigs must have a stand alone SPCC that travels with the drilling rig where ever it goes). The SPCC must be coupled with a Flow Line Contingency Paln in order for the SPCC to be valid. 

Flow Line Contingency Plan

The Flow Line Contingency Plan or FLCP is an EPA mandated  emergency plan that all facilities with flow lines outside of containment must have in order for the SPCC to be considered valid. 

When these plans are done properly they are designed to let you know the age of your equipment, how well managed your site is, and what your risk is of having an emergency situation on site and what you are to do should an emergency of any kind arise. They should tell you quickly where the site is, how to get there and where any fluids are going to go and what you will need to mitigate the situation. You should be able to take your SPCC/FLCP and create a schedule of repair and replacement for your equipment so that your risk in operations is lowered and the value of your investment is raised.

If you don't have an SPCC / FLCP you can be issued a fine of up to 37, 500.00 per day by the EPA if there is an emergency situation that develops on site such as a spill. If you simply go over the EPA  fine schedule of 2,500.00 for your facility you will have a mandatory Federal Court appearance.

I can't over emphasize the importance of the Phase 1 Survey when you are purchasing any property, This document breaks the chain of responsibility between you and the previous owners for any potential environmental issues. To give you an example of the seriousness, I called a potential client who had just purchased a property and the next day the EPA arrived and she became responsible for all the Salt Scald on her new property which wound up costing her 200,000.00 to clean up. If she had a Phase 1 survey done she would have been spared that cost that she said it will take her over 20 years to recoup that cost. for lack of a 1,200.00 plan she faced a 200K bill.

These plans are often necessary when a site has hazardous working conditions such as high levels of H2S or the sites are in sensitive areas such as marshes or federally protected areas. Sometimes a company chooses to have this done in order to qualify for cheaper insurance. So theses can be a  way to mitigate losses during an emergency or manage operating expenses during day to day operations.

A Site Closure plan is often mandated by the regulatory agencies and will let them know that plans have been put in place for the eventual closure of the site and all clean up necessary to bring the site back into  its natural state.

Permitting is often a real pain because the regulatory agencies have no real  idea of what goes on out in the field and the paperwork can be very complex. Oftentimes it makes sense to employ a person who can take the time and knows how to work with the regulatory agencies to expedite the process and seve you time and money.