SPCC Plan Regulations & FAQs

Do You Need an SPCC Plan?

Your facility must have an SPCC Plan if it meets both conditions:

• Oil Storage Thresholds

  • Aboveground storage capacity of 1,320 gallons or more in containers 55 gallons or larger, or

  • Underground storage capacity of 42,000 gallons or more.

• Spill Risk

  • There is a reasonable expectation that an oil spill could reach navigable waters or adjoining shorelines (through drainage, ditches, storm sewers, or soil flow).

Important: The EPA does not consider man-made barriers (like dikes or berms) when deciding if oil could reach water. Applicability is based on location and storage only.

This means farms, factories, warehouses, trucking companies, construction sites, and energy facilities are all commonly covered.

What Does an SPCC Plan Include?

A compliant SPCC Plan is more than a binder on the shelf—it’s a working safety plan tailored to your site. According to EPA rules and industry best practices, your plan will cover:

• Facility & Site Information – layout, oil storage locations, and drainage patterns.

• Spill Prevention Measures – inspection schedules, tank integrity testing, and employee training.

• Control & Countermeasures – containment strategies and cleanup procedures.

• Emergency Contacts & Response Protocols – step-by-step actions to take during a spill.

• Secondary Containment – structures or equipment capable of holding the largest single container plus rainfall allowance.

• Certification – depending on your facility size, your plan may need to be signed off by a licensed Professional Engineer (PE).

Who Can Prepare an SPCC Plan?

The EPA uses a tiered approach:

• Tier I Qualified Facilities

  • Total oil storage ≤10,000 gallons.

  • No single container greater than 5,000 gallons.

  • Eligible to prepare a self-certified Plan using EPA’s template.

• Tier II Qualified Facilities

  • Still ≤10,000 gallons total but with larger single containers.

  • Can self-certify but need a more detailed Plan.

• PE-Certified Facilities

  • Facilities over 10,000 gallons, or those with significant risk history, must have a Professional Engineer certify their Plan.

New facilities must prepare and implement an SPCC Plan within one year of startup.

Why Compliance Is Critical

Having a certified SPCC Plan in place protects you from:

• EPA Fines & Penalties – which can cost thousands per day.

• Costly Spill Cleanup – prevention costs less than remediation.

• Operational Delays – non-compliance can stop projects in their tracks.

• Liability & Reputation Damage – spills can harm your brand, environment, and community trust.

Frequently Asked Questions About SPCC Plans

1. How often must my SPCC Plan be updated?
At least once every five years, or sooner if you add new tanks, change operations, or modify your facility.

2. Can farms be required to have SPCC Plans?
Yes. Farms with qualifying fuel tanks, oil drums, or chemical containers must comply if they meet EPA thresholds.

3. What happens during an EPA inspection?
Inspectors will:

• Review your SPCC Plan.

• Verify your oil storage matches the documentation.

• Inspect your secondary containment and spill prevention practices.

4. How fast must a new facility comply?
Within one year of starting operations, an SPCC Plan must be written and implemented.

5. What if my facility has less than 1,320 gallons?
You’re not subject to SPCC requirements—but keeping a basic spill protocol is still smart risk management.

Ready to Get Your SPCC Plan in Place?

Don’t wait for an inspection or a spill to highlight the gaps. A properly prepared SPCC Plan keeps your facility compliant, protects the environment, and saves you money in the long run.

Contact us today to start your SPCC Plan consultation and ensure you meet every EPA requirement with confidence.