SPCC Plans: Does Your Facility Need One?

5 min read

A lot of facility managers have heard the term “SPCC plan” without ever being sure whether it applies to them. The short version: if your site stores enough oil — and “oil” is defined broadly here, covering everything from diesel and hydraulic fluid to lubricants and used oil — in a way that could reasonably reach a waterway if it spilled, you likely need one.

The storage threshold

Under the EPA’s Oil Pollution Prevention regulation (40 CFR Part 112), a facility generally needs a written Spill Prevention, Control, and Countermeasure (SPCC) plan if it has an aggregate aboveground oil storage capacity greater than 1,320 gallons, or completely buried storage capacity greater than 42,000 gallons, and there’s a reasonable expectation that a spill could reach navigable waters or an adjacent shoreline. That 1,320-gallon aboveground threshold adds up faster than people expect — it’s counted across every container 55 gallons or larger on-site, including drums, totes, generator day tanks, and hydraulic reservoirs, not just a single large tank.

What the plan actually covers

An SPCC plan documents your facility’s oil storage locations, spill prevention measures (secondary containment, drainage controls, inspection schedules), and the specific countermeasures your team would take in the event of a discharge. It’s a working document, not a shelf filler — it needs to reflect what’s actually on-site, and it has to be reviewed and amended when storage capacity or facility layout changes materially.

Who can certify it

Most SPCC plans must be reviewed and certified by a licensed Professional Engineer (PE), who attests that the plan follows accepted engineering practices and meets the regulation’s requirements. There’s a self-certification option for smaller facilities — generally those with 10,000 gallons or less of aggregate aboveground storage and a clean spill history — but the qualifying criteria are specific, and getting that determination wrong is its own compliance risk.

Why this gets missed

SPCC plans tend to fall through the cracks at facilities where oil storage grew gradually — a few more totes here, a backup generator there — without anyone stepping back to add up the total. It’s also common at facilities that assume, incorrectly, that being far from a visible creek or river means they’re not near “navigable waters,” a term that’s interpreted more broadly than most people expect, including storm drains that connect to waterways.