| name | spcc-plan |
| title | SPCC Plan Drafting |
| description | Drafts a Spill Prevention, Control, and Countermeasure (SPCC) Plan compliant with 40 CFR Part 112 under the Clean Water Act. Covers facility characterization, oil storage inventory, secondary containment, prevention measures, response procedures, training, and PE certification language. Use when drafting SPCC plans, oil spill prevention documents, or EPA compliance submissions. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/spcc-plan |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | environmental |
| language | en |
SPCC Plan Drafting
Generates a 40 CFR Part 112-compliant SPCC Plan for facilities storing oil in quantities that could discharge into navigable waters or adjoining shorelines.
Prerequisites
Gather before drafting:
- Facility tier — Tier I (qualified: ≤10,000 gal total, no single tank >5,000 gal, no discharge history in past 3 years), Tier II, or PE-certified
- Site documentation — coordinates, site plans, engineering drawings, topographic/drainage maps
- Oil storage inventory — tank types, capacities, oil types, ages, materials, locations
- Spill history — prior SPCC plans, inspection reports, discharge records
- Emergency contacts — facility coordinator, responders, cleanup contractors, NRC number
Quick Start
- Classify the facility tier and determine certification path (PE vs. self-certification)
- Build the oil storage inventory table from client data
- Calculate secondary containment volumes per the 110%/10% rule
- Draft the tiered spill response matrix
- Produce training schedule, inspection program, and recordkeeping plan
- Add certification/attestation block matching the facility tier
- Compile appendices (site maps, calculations, checklists, contact lists)
Plan Sections
1. Introduction & Regulatory Basis
Table with: facility name/owner/operator/address/coordinates, regulatory basis (40 CFR Part 112; CWA §311), facility tier with justification, and plan objectives.
2. Facility Characterization
Document coordinates, proximity to navigable waters, topography, drainage patterns, all discharge pathways (storm drains, ditches, culverts, overland flow), seasonal variations. Reference uploaded site maps.
3. Oil Storage & Equipment Inventory
Tabulate each container: type (AST/UST/mobile/drum/IBC), oil type and characteristics, max and typical capacity (gal), construction material, age/condition, location keyed to site map. Include aggregate and individual capacities per 40 CFR 112.7.
4. Spill Prevention & Containment
Secondary containment rule: each area must hold the greater of 110% of largest single tank OR 10% of total aggregate capacity. Show volume calculations.
Document per storage area:
