Wednesday, May 26, 2010

Difference Between SPCC SWPPP SWP3 Plans

What is the Difference Between a SPCC Plan and a SWPPP Plan?
Some municipal and industrial sites may be required to prepare and implement either a SPCC Plan, a SWPPP Plan, or both. SPCC Plans and SWPPP Plans are different documents, requiring different types of information, and are required under different regulatory programs.

SPCC Plans. SPCC Plans are required under the federal Oil Pollution Control Act, and the requirements are specified in 40 CFR 112 ("SPCC Rule"). In order to determine if SPCC Rules apply to an individual site, an inventory of oil and fat containing vessels, which may include oil-filled equipment, must be made. The results are compared to the SPCC threshold. If the site exceeds the threshold, a SPCC Plan needs to be prepared and the site needs to comply with other aspects of the SPCC Rule.

SWPPP Plans. Stormwater Pollution Prevention Plans ("SWPPP Plans", or "SWP3 Plan") are required by the federal Clean Water Act, specifically under requirements for National Pollutant Discharge Elimination System (NPDES). The requirement to prepare and implement a SWPPP, and the contents of the SWPPP, will be defined in an NPDES permit. Many industrial, municipal and construction sites are required to obtain an NPDES permit to discharge stormwater, and are therefore required to have a SWPPP.

The SWPPP and SPCC Plan can be related; most SWPPPs need to incorporate procedures for spill prevention and response. Sites that are required to have a SPCC Plan can use that plan to satisfy this one requirement, as long as the oils and fats addressed in the SPCC Plan are the only materials that need to be addressed in the SWPPP.  In summary, sites could need either a SPCC Plan, a SWPPP, or both.

For more information on Caltha LLP SWPPP services, go to the Environmental Health & Safety Plan | Spill Plan Information Request Form.

Caltha LLP provides expert consulting services to public and private sector clients nationwide to address preparation of SPCC Plans and 40 CFR 112 Compliance Programs, preparation of Stormwater Pollution Prevention Plans (SWPPP), and SPCC Training and SWPPP Training. For further information contact Caltha LLP at

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