If your facility stores oil or petroleum products in IBC totes and your total above-ground storage capacity exceeds 1,320 gallons, you are likely subject to EPA Spill Prevention, Control, and Countermeasure (SPCC) regulations under 40 CFR Part 112. Non-compliance can result in significant fines and liability.
Do You Need an SPCC Plan?
An SPCC plan is required if your facility meets ALL of the following: it is non-transportation-related, it stores oil or petroleum products, the total above-ground storage capacity exceeds 1,320 gallons or total underground capacity exceeds 42,000 gallons, and there is a reasonable expectation that a discharge could reach navigable waters or adjoining shorelines.
Note that "oil" under SPCC is broadly defined and includes not just petroleum crude but also fuel oil, lubricants, vegetable oils, animal fats, synthetic oils, and mineral oils. If your IBCs contain any of these products, they count toward your aggregate storage capacity.
Secondary Containment Requirements
The cornerstone of SPCC compliance for IBC storage is secondary containment. The containment system must be capable of holding the volume of the single largest container plus sufficient freeboard for precipitation. For practical purposes, most facilities design containment to hold 110% of the largest IBC.
Containment options include prefabricated IBC containment pallets (available in single and quad configurations), bermed areas with impervious flooring, and custom-built containment structures. The containment must be constructed of materials compatible with the stored products.
Inspection and Maintenance
SPCC plans require regular inspection of storage areas and containment systems. IBCs should be inspected for leaks, corrosion, and valve integrity on a scheduled basis. Containment areas must be checked for cracks, standing liquid, and drainage functionality. All inspections must be documented with date, inspector name, and findings.
Training Requirements
All personnel who handle, store, or transport oil-containing IBCs must receive SPCC training. This includes initial training for new employees and annual refresher training. Training should cover spill prevention procedures, emergency response protocols, and the specific contents of your facility's SPCC plan.