If your facility stores more than 1,320 gallons of oil in above-ground containers or more than 42,000 gallons underground, federal law requires you to have a Spill Prevention, Control, and Countermeasure plan. Most facilities that need one either don't have one or have a dusty binder from 2018 that no longer matches reality.
A SPCC plan is a federally required document under 40 CFR Part 112 (the Clean Water Act's oil pollution prevention regulation). It identifies every oil storage container at your facility, evaluates the risk of a spill reaching navigable waters, and lays out the specific prevention measures, containment systems, and response procedures in place to stop that from happening.
"Oil" under SPCC is broadly defined. It covers petroleum products (diesel, gasoline, motor oil, hydraulic fluid), animal fats, vegetable oils, and other non-petroleum oils. If you have a 300-gallon diesel day tank, a 500-gallon used oil tank, a 275-gallon hydraulic oil reservoir, and a couple of 55-gallon drums of motor oil, you are probably over the 1,320-gallon threshold and need a plan.
Any facility that stores oil above the threshold amounts and could reasonably be expected to discharge oil into or upon navigable waters or adjoining shorelines. "Navigable waters" is interpreted broadly by EPA. If your facility has storm drains, ditches, creeks, or any drainage that eventually reaches a waterway, you likely qualify.
This catches a lot of facilities that don't think of themselves as "oil storage" operations. Manufacturing plants with hydraulic systems, fleet maintenance shops with used oil tanks, backup generator fuel tanks, transformer oil, heating oil tanks, even restaurants with large grease storage can trigger the requirement.
Facilities that qualify for the Tier I qualified facility exemption (1,320 gallons or less total, no single container over 55 gallons, no reportable spills in the last 3 years) can self-certify a simplified plan. Everyone else needs the full plan, and most full plans require Professional Engineer (PE) certification.
A compliant SPCC plan includes a facility diagram showing all oil storage containers and their capacities, a description of each container's secondary containment system, spill history for the past 12 months, predictions of the direction and flow rate of potential spills, a description of containment and diversionary structures, inspection schedules and procedures, personnel training requirements, and emergency contact information.
The plan must be specific to your facility. A generic template with your company name pasted in does not meet the regulatory requirement. The plan has to describe your actual containers, your actual containment, your actual drainage, and your actual procedures. EPA inspectors know what a template plan looks like, and they will cite you for it.
If your facility does not qualify for the Tier I or Tier II qualified facility exemptions, the SPCC plan must be reviewed and certified by a licensed Professional Engineer. The PE certifies that the plan has been prepared in accordance with good engineering practice, that the containment systems are adequate, and that the plan meets the requirements of 40 CFR 112.
Not every environmental consultant has a PE on staff. When shopping for SPCC plan services, confirm that a licensed PE will review and stamp the plan. A plan without the required PE certification is treated the same as not having a plan at all.
SPCC plans must be reviewed and amended within six months of any change at the facility that affects the plan's effectiveness. That includes adding or removing storage tanks, changing containment structures, modifying drainage patterns, or changing the types of oil stored. The amended plan needs a new PE certification.
Even without changes, the plan should be reviewed at least every five years and updated to reflect current conditions. In practice, most facilities go through equipment changes, layout modifications, and personnel turnover frequently enough that the plan drifts out of compliance well before the five-year mark.
SPCC plan preparation by a qualified environmental consultant typically runs $2,000-8,000 for a standard industrial facility. Complex sites with dozens of containers, multiple buildings, or complicated drainage can run $10,000-20,000 or more. PE certification is usually included in the consultant's fee. Plan amendments for minor changes run $500-2,000.
Compare that to the penalty for not having a plan: up to $2,563 per barrel of oil discharged, plus $71,545 per day for failure to prepare or implement a SPCC plan. A single inspection finding can exceed the cost of a plan by an order of magnitude.
Read our detailed guide: Your SPCC Plan Is Gathering Dust. Here's What That Costs You. It covers the most common ways SPCC plans fall out of compliance and what EPA looks for during an inspection.
For a full breakdown of federal penalty amounts, see our Penalties Lookup Tool.
