What Is an SPCC Plan?
A Spill Prevention, Control, and Countermeasure (SPCC) Plan is a federally required document under the U.S. Environmental Protection Agency’s Oil Pollution Prevention regulations in 40 CFR Part 112. Its purpose is to prevent oil spills from reaching navigable waters or adjoining shorelines.
Facilities that store or handle oil, including petroleum, diesel, lubricants, hydraulic fluids, or oily wastewater, must implement an SPCC plan if they exceed specific storage thresholds. The plan outlines spill prevention practices, inspection procedures, containment structures, and response protocols to minimize environmental impact from oil-related incidents.
For industrial sites, utilities, transportation yards, warehouses, and municipal facilities, SPCC compliance is not optional. It is a core environmental obligation.
Which Facilities Need an SPCC Plan?
A facility must comply with SPCC regulations if it:
- Stores 1,320 gallons or more of oil aboveground, or
- Stores 42,000 gallons or more of oil underground, not already regulated as underground storage tanks, and
- Has a reasonable expectation that spilled oil could reach navigable waters or shorelines
“Reasonable expectation” is interpreted broadly. Even facilities several miles from waterways may fall under SPCC if drainage pathways could channel a spill toward water.
Typical facilities requiring SPCC plans include:
- Industrial manufacturing sites
- Transportation and logistics yards
- Fuel depots and fleet maintenance facilities
- Electric utilities and substations
- Waste management and recycling facilities
- Agricultural and food processing operations
- Construction sites with temporary fuel storage
Key Components of an SPCC Plan
A compliant SPCC plan must be facility-specific and prepared according to EPA standards. Required elements include the following.
Facility diagram and oil inventory: The plan must contain a detailed site map indicating aboveground storage tanks, drums, totes, mobile containers, transfer areas, loading and unloading zones, drainage pathways, and secondary containment structures. Oil storage capacities must be listed for each container.
Spill prevention measures: This section outlines operational controls designed to prevent spills, such as regular tank and piping inspections, integrity testing, preventive maintenance schedules, overfill prevention devices, and employee training programs.
Secondary containment: SPCC rules require containment systems capable of capturing the full volume of the largest container, plus any precipitation. Common secondary containment systems include concrete berms, double-walled tanks, spill pallets, earthen dikes, and impermeable liners.
Spill response procedures: An SPCC plan must document how the facility will contain, control, and clean up an oil spill, including immediate actions to stop the release, notification requirements, deployment of spill kits and absorbents, emergency contact lists, and waste disposal procedures.
Training and recordkeeping: Facilities must provide annual SPCC training for personnel involved in oil handling or response activities. Documentation must be kept for inspection.
Professional Engineer certification: Most SPCC plans require certification by a licensed Professional Engineer. A PE verifies that the plan meets all technical requirements and that containment systems are adequately designed. Smaller facilities with limited oil quantities may qualify for self-certified SPCC plans under Tier I or Tier II categories.
Inspections and Maintenance Requirements
SPCC compliance is ongoing. EPA expects facilities to:
- Conduct routine inspections of tanks, valves, hoses, and piping
- Maintain spill kits and response materials
- Ensure containment systems remain intact and functional
- Perform integrity testing at required intervals
- Document all inspections and maintenance activities
Lack of documentation is one of the most common reasons facilities fail SPCC audits.
Common SPCC Violations
During regulatory inspections, the EPA frequently cites facilities for:
- Missing or outdated SPCC plans
- Plans that are not site-specific
- Lack of secondary containment
- Untrained personnel
- Failure to perform routine inspections
- Missing calculation of oil storage capacities
- Poor housekeeping near tanks or filling areas
Correcting these issues after an inspection can be costly. Proactive compliance is the better strategy.
Best Practices for SPCC Compliance
Facilities can strengthen their SPCC programs by:
- Updating the SPCC plan immediately after operational changes
- Standardizing inspection checklists for field teams
- Installing alarms or automatic shutoff devices
- Improving housekeeping around loading and transfer areas
- Implementing preventive maintenance schedules
- Ensuring spill kits are properly stocked and accessible
- Conducting annual spill response drills
These best practices not only prevent spills but also improve regulatory confidence and reduce risk.
How O6 Environmental Helps Facilities Stay Compliant
O6 Environmental provides comprehensive SPCC compliance support, including:
- SPCC plan development and updates
- Oil storage audits and inventory documentation
- Facility diagrams and secondary containment evaluations
- Professional Engineer certified plan preparation where required
- Employee training programs
- Spill response readiness assessments
- Ongoing inspection and maintenance support
Our team ensures your facility meets all EPA and state-specific requirements while reducing the risk of costly spills or enforcement actions.
Protecting Waterways and Facility Operations
SPCC compliance is more than a regulatory obligation. It is a critical part of responsible facility management. A well-designed and actively maintained SPCC plan protects waterways, reduces operational risks, and demonstrates a commitment to environmental stewardship.
With O6 Environmental as your compliance partner, you can maintain safe operations and stay ahead of regulatory expectations year-round.
