The Spill Prevention, Control, and Countermeasure (SPCC) rule under 40 CFR Part 112 requires facilities that store oil in regulated quantities to prepare, maintain, and implement a written SPCC plan. The plan is the foundation of your entire spill prevention program: it documents what oil you store, how it is contained, how you prevent discharges, and what you do if a spill occurs. This guide covers who needs a plan, what it must contain, the different plan types available, and how SPCC software simplifies plan development and maintenance.
Common SPCC Plan Challenges
Who Needs an SPCC Plan?
Applicability Criteria (40 CFR § 112.1)
A facility must prepare and implement an SPCC plan if it meets all three of the following criteria:
- Non-transportation-related - The facility is not solely engaged in transportation of oil (pipelines, vessels, rail cars, trucks in transit)
- Oil storage capacity thresholds - Aggregate aboveground oil storage capacity exceeds 1,320 gallons, or completely buried storage capacity exceeds 42,000 gallons
- Reasonable expectation of discharge - The facility could reasonably be expected to discharge oil in quantities that may be harmful to navigable waters or adjoining shorelines
Counting Your Storage Capacity
When determining if you exceed the 1,320-gallon threshold, count the shell capacity (maximum volume) of all aboveground oil storage containers at the facility, including:
- Aboveground storage tanks (ASTs) of all sizes
- Drums, totes, and intermediate bulk containers (IBCs) with individual capacities of 55 gallons or more
- Oil-filled operational equipment (transformers, hydraulic systems) with capacities of 55 gallons or more
- Mobile or portable containers stored at the facility
Use our Tank Volume Calculator to determine shell capacities for standard tank geometries.
SPCC Plan Types
The SPCC rule provides three plan types based on facility size and spill history. Selecting the correct type is critical because it determines whether you need a Professional Engineer (PE) to certify the plan.
Full SPCC Plan (40 CFR § 112.3-112.7)
Required for any facility that does not qualify as a Tier I or Tier II qualified facility. Must be reviewed and certified by a licensed Professional Engineer. Contains the full range of required elements including facility-specific engineering analysis, containment calculations, and discharge prevention measures.
Tier I Qualified Facility Plan (40 CFR § 112.6(a))
A simplified, self-certified plan using the EPA-provided template. Available to facilities meeting all of these criteria:
- Total aboveground oil storage capacity of 10,000 gallons or less
- No single discharge exceeding 1,000 gallons in the past three years
- No two discharges each exceeding 42 gallons within any 12-month period in the past three years
The facility owner or operator certifies the plan. No PE review is required.
Tier II Qualified Facility Plan (40 CFR § 112.6(b))
A self-certified plan that allows more flexibility than Tier I but still does not require PE certification. Same eligibility criteria as Tier I (10,000 gallons or less, clean spill history). The owner or operator prepares the plan following the general SPCC plan requirements rather than the EPA template, and self-certifies it.
Required SPCC Plan Contents
Every SPCC plan, regardless of type, must address the elements specified in 40 CFR § 112.7. The following are the core requirements:
Facility Information and Diagrams
- Facility name, address, and contact information
- Facility diagram showing all oil storage containers, transfer stations, connecting pipes, containment structures, and drainage patterns
- Identification of nearby navigable waters and the drainage path from the facility
- Description of the facility's oil storage and handling operations
Oil Storage Container Inventory
- Complete list of all oil storage containers with type, capacity, contents, and location
- Total facility oil storage capacity (aboveground and buried separately)
- Container construction details (material, age, manufacturer where known)
SPCC software generates this inventory automatically from your container database, keeping it current as equipment changes.
Secondary Containment (40 CFR § 112.7(c))
The plan must describe secondary containment for each oil storage area, including:
- Type of containment (dike, berm, double-wall tank, drainage tray, retention pond)
- Containment capacity and adequacy calculations demonstrating it can hold the volume of the largest container plus sufficient freeboard for precipitation
- Drainage controls and valve management procedures
Use our Containment Volume Calculator to verify capacity.
Inspections, Testing, and Maintenance
- Inspection procedures and schedules for containers, containment, pipes, and equipment
- Integrity testing methods and intervals (STI SP001, API 653, or equivalent)
- Maintenance procedures for tanks, valves, pipes, and containment systems
- Documentation and recordkeeping procedures (records retained at least 3 years)
Discharge Prevention and Response
- Discharge prevention measures for each type of oil handling operation (bulk transfers, loading/unloading, process operations)
- Overfill prevention procedures (high-level alarms, automatic shut-off devices, operator monitoring)
- Spill notification procedures including contacts for NRC, state agencies, and local responders
- Spill response equipment and procedures, including regulatory reporting requirements
Personnel Training and Security
- Training procedures for oil-handling personnel covering spill prevention, containment, and response (40 CFR § 112.7(f))
- Facility security measures to prevent unauthorized access and vandalism (40 CFR § 112.7(g)): fencing, lighting, locks, signage, and access controls
PE Certification Requirements
Five-Year Review Requirement (40 CFR § 112.5(b))
Mandatory Plan Review
Every SPCC plan must be reviewed and evaluated at least once every five years from the date of the last review. The review must determine whether the plan still reflects current facility conditions, operations, and regulations. If changes are needed, the plan must be amended, re-certified (by PE if applicable), and implemented. Even if no changes are needed, the five-year review must be documented with the date and conclusion that no amendments were necessary.
Amendment Triggers (40 CFR § 112.5(a))
When You Must Amend the Plan
An SPCC plan must be amended whenever there is a change in facility design, construction, operation, or maintenance that materially affects the potential for a discharge. Common triggers include:
- Adding, removing, or replacing oil storage containers
- Changing container contents, capacity, or location
- Modifying secondary containment systems
- Changing transfer operations or piping configurations
- Facility expansion or change in operations
- A spill event that reveals plan deficiencies
Amendments to full plans must be PE-certified and implemented within six months of the triggering change.
Ecesis SPCC Software
SPCC Software
Container management, plan generation, containment calculations, and compliance tracking.
Inspection Software
Automated scheduling, mobile field inspections, and audit-ready documentation.
Preventive Maintenance
Track tank maintenance, work orders, and equipment lifecycles.
Employee Training
Manage SPCC training requirements and oil-handling certifications.
Chemical Management
SDS library and chemical inventory alongside oil storage management.
Mobile EHS App
Field inspections, incident reporting, and data collection from any device.
