SPCC Plan Author (40 CFR 112)

Example Conversation

You: We have a small maintenance yard with three 1,000-gallon diesel ASTs, a 275-gallon used-oil tote, no spills in the last three years, and drainage to a ditch that reaches a creek. Can you draft a Tier I SPCC Plan?

Agent: I’ll first screen SPCC applicability and Tier I eligibility. I’ll count aboveground oil containers of 55 gallons or more, check the 1,320-gallon threshold, confirm that no counted container exceeds 5,000 gallons, and document the clean discharge-history assumption.

Agent: Based on your facts, I’ll prepare a Tier I-style package with management approval, container inventory, diagram narrative, containment worksheet, inspection schedule, response notifications including NRC 1-800-424-8802, training log, five-year review attestation, and a 40 CFR Part 112 cross-reference matrix.

Agent: I’ll run spcc_eligibility_assessor, use spcc_containment_sizer where containment volumes are available, and finish with spcc_completeness_checker before handing the plan to your owner/operator and any required professional reviewer.

Sample Output Excerpt

Excerpt from a generated SPCC Plan package.

# Spill Prevention, Control, and Countermeasure Plan

Prepared for: [Facility / Operator]
Plan track: Tier I qualified facility — draft pending owner/operator certification
Effective date: [date]
Last 5-year review: [date]

## Applicability Summary

- Facility type: non-transportation-related maintenance yard
- Counted aboveground oil capacity: 3,275 gallons
- Completely buried oil capacity: 0 gallons
- Reasonable discharge potential: drainage ditch to [receiving creek]
- Discharge history: no qualifying discharges reported in prior 3 years [verify]

## Oil-Container Inventory

| ID     | Location         | Contents |  Capacity | Secondary containment | Inspection basis                       |
| ------ | ---------------- | -------- | --------: | --------------------- | -------------------------------------- |
| AST-1  | Fuel island      | Diesel   | 1,000 gal | Concrete berm         | Visual inspection / facility procedure |
| AST-2  | Fuel island      | Diesel   | 1,000 gal | Concrete berm         | Visual inspection / facility procedure |
| AST-3  | Fuel island      | Diesel   | 1,000 gal | Concrete berm         | Visual inspection / facility procedure |
| TOTE-1 | Maintenance shop | Used oil |   275 gal | Spill pallet          | Visual inspection                      |

## Secondary Containment Worksheet

Required volume = largest container + precipitation/freeboard allowance.
Available volume and engineering basis: [evidence required]

Extension Tools

spcc_eligibility_assessor screens container capacity and discharge-history inputs to identify likely federal SPCC capacity applicability and the draft certification track: below threshold, Tier I qualified facility, Tier II qualified facility, or PE-certified plan.

spcc_containment_sizer calculates largest-container secondary-containment volume plus precipitation/freeboard allowance and compares it with available containment capacity for each area.

spcc_completeness_checker checks an SPCC draft file or package directory for required drafting signals: applicability, certification track, facility/operator profile, site diagram and drainage, oil-container inventory, secondary containment, inspections and integrity testing, transfer/loading controls, discharge response and NRC notification, training, five-year review, FRP screening, and 40 CFR Part 112 cross-reference matrix.

Getting Started

Add facility facts to the workspace: site profile, oil-container inventory, SDS/oil list, site plan or drainage sketch, containment dimensions, spill history, inspection records, training records, emergency contacts, and prior SPCC Plans. Then ask the skill to screen applicability, draft a Tier I/Tier II/PE-ready package, or update the plan for a five-year review.