Everything You Need to Know About SPCC Plans

The Complete Guide to SPCC Plans: What They Are, Who Needs One, What's Covered, Requirements, Costs, Timelines, and More!

Is your facility storing oil, but you're not sure what regulations apply? Heard about SPCC plans, but never really dug into the details? Just looking for a refresher?

If so, you're in the right place - we're about to cover everything (and I mean absolutely everything) you could possibly need to know about SPCC plans & regulations. Consider this the modern day starting guide to understanding these poorly enforced regulations.

By the end of this wall of text (or the video below!) you'll understand what SPCC plans are and know exactly where your compliance falls with SPCC regulations.

And if you still have questions and want to pick an expert's brain - reach out to us, we're more than happy to chat. Okay, let's jump in to the what, why, who, how, and everything else there is to know about SPCC plans.

SPCC Plan Basics: What They Are and Why They Matter

• What SPCC Plans Are
• Who Needs an SPCC Plan
• The Three Types of SPCC Plans
• What Kinds of Oils Are Covered
• How to Get an SPCC Plan
• How Much an SPCC Plan Costs
• How Long It Takes to Get a Plan
• What You Actually Have to Do With Your Plan
• What’s New With SPCC Plans in 2025
• Final Thoughts & Next Steps

What is an SPCC Plan?

SPCC stands for Spill Prevention, Control, and Countermeasure, and it’s a federal regulation under the Clean Water Act, specifically 40 CFR Part 112, and it’s enforced by the U.S. Environmental Protection Agency (EPA).

Now that might already sound like mumbo jumbo, but the idea is simple: if you store oil on your property, you may need a plan in place to prevent it from spilling, and to respond quickly and effectively if it does.

Think of it kind of like a fire escape plan, but for oil. Instead of waiting until there’s an emergency to figure out who does what, your SPCC Plan spells out:

• Where oil is stored
• How to prevent spills
• What to do if there is a spill
• Who is responsible for each part of the response
• And more!

Each plan is unique to your specific site, and no two should be the same. In a nutshell, it’s your facility’s roadmap for keeping oil out of waterways and avoiding expensive fines, environmental damage, and public safety issues.

Okay, but what is it really?

It’s a document. Like, an actual physical thing. In most cases, it’s a book, binder, or printed report that lives on-site at your facility.

You can keep a copy stored digitally (many of our clients do) but here’s the catch: you also need a physical copy available and accessible at your site. Why? Because if there’s an emergency, a power outage, the internet's down, the guy with the shared drive login info is out sick, or a regulatory inspection, you can’t risk your only plan being stuck somewhere digitally.

We always recommend keeping at least one printed, up-to-date version in a spot where staff can grab it quickly. Ideally, somewhere near your main office, control room, evacuation point, your "mobile office" (aka your car), or wherever your emergency response equipment is stored.

What's in an SPCC Plan?

Every SPCC Plan is unique to the facility, but there are a few key elements that must be included no matter what. At a minimum, your plan should cover:

• A description of oil, the storage locations, and overall capacities
• Diagrams or site maps showing where oil is stored and how spills could flow
• Details on spill prevention measures and secondary containment
• Step-by-step spill response procedures
• Contact info for emergency responders and internal personnel
• Inspection and maintenance routines
• Staff training procedures
• Recordkeeping requirements

In short, it’s your site-specific strategy for preventing, responding to, and documenting anything that could go wrong with oil handling.

Who Needs an SPCC Plan?

Let’s start with the basics. The SPCC rule applies to any facility that:

• Has the capacity to store more than 1,320 gallons of oil aboveground in containers 55 gallons or larger, or stores 42,000 gallons or more in underground tanks
• Has a reasonable expectation of a discharge into navigable waters or adjoining shorelines.
• Is considered part of the non-transportation sector. That means if you’re not actively transporting oil (like via pipeline, barge, or rail) you fall under SPCC regulations.

That third point surprises a lot of people. SPCC doesn’t just apply to oil terminals or refineries. It’s meant for any facility that stores oil as part of its operations, not for transport. But more on that shortly.

Capacity to Store Thresholds: What Really Matters?

When it comes to SPCC Plans, what matters isn’t how much oil you usually have on hand, it’s how much you could store at any one time.

That means the EPA is looking at your maximum storage capacity, not your average inventory. So if you have a 2,000-gallon tank that’s only filled halfway most of the time? You’re still over the 1,320-gallon threshold. It’s the tank’s capacity that counts, not how much oil you actually have in it!

This also means smaller containers can sneak up on you. 55-gallon drums are included, and they’re everywhere. Just 24 drums is enough to put you over the 1,320-gallon threshold. If you’ve got a few pallets of oil drums sitting out back, you’re probably already required to have an SPCC Plan, even if you’ve never thought of yourself as an “oil-heavy facility.”

There's considerations around things like oil-filled equipment (like a transformer) or reservoirs and tanks built into equipment. There's also mobile equipment that can be evaluated depending on particulars. Typically if you're trying to figure out whether these other oil-bearing pieces of equipment are included, you're probably looking at needing outside help to put your plan together regardless.

The bottom line: if your containers could hold more than 1,320 gallons of oil, you need to take SPCC regulations seriously.

Reasonable Expectation to Discharge to a Navigable Water: What Actually Counts?

Navigable waters sound straightforward, right? Rivers, lakes, bays or maybe the ocean. But in the world of environmental compliance, the definition is way broader. According to the EPA, navigable waters can also include small streams, creeks, ponds, and wetlands - even if they're dried up for the season.

And here’s the tricky part: even if you don’t see a water body on the map, oil can still make its way there. Storm drains - the ones right outside your building in the street - can carry spilled oil for miles. If spilled oil can make its way to a storm drain, and eventually into a navigable water, the EPA says that counts. That’s what they call a “reasonable expectation of discharge.”

Basically, if there’s any chance spilled oil could move off your site and eventually reach a waterbody (even indirectly) you meet the second condition (and let's be honest, there probably is). We’ve seen sites argue they’re too remote to count, only to have regulators say otherwise. When in doubt, assume the rule applies everywhere, because for the most part it does.

Non-Transportation Sector: What Kinds of Facilities Are Covered?

This regulation is not just for the oil and gas industry. Remember, it's anyone outside of the core oil-transportation industry, places like:

• Manufacturing & fabrication facilities with various types of oils
• Warehouses & distribution centers with generators, fueling stations, and more
• Concrete, asphalt plants, and mining with fueling stations, garages, hydraulic oil reservoirs in equipment, and more
• Marinas & bus services with fueling stations, garages, and more
• Recycling & scrapyards with used oil, fueling stations, and garages
• Data centers & tech hubs with backup generators and transformers
• Commercial and government office buildings again, backup generators and transformers!
• Hospitals, schools, etc. Tired of reading "backup generators and transformers" yet?
• Food production & processing facilities, even farms with various types of oils

And this isn't an all-inclusive list. The possibilities are endless. Moral of the story: if you’ve got oil on-site, and you’re not actively moving it by rail, truck, or pipe, you likely fall under this rule.

The Three Types of SPCC Plans

Not every facility needs the same type of plan. The EPA offers a tiered system based on how much oil you store and how big your containers are. Here's how it breaks down:

Tier I: The Simplest, Self-Certified Plan

If your facility stores less than 10,000 gallons of oil in total and no single container is larger than 5,000 gallons, you qualify for a Tier I plan. This version is self-certified, meaning you don’t need a Professional Engineer (PE) to review it. It’s the most straightforward option, and great for small businesses or low-risk facilities.

Tier II: Still Self-Certified, But for Larger Containers

If you still store less than 10,000 gallons, but one or more of your containers is over 5,000 gallons, you fall under Tier II. This is still a self-certified plan, but the EPA requires more detail. It’s a little more work than Tier I, but still manageable.

Full PE-Certified Plan: For Large or Complex Facilities

If your facility stores 10,000 gallons or more, or if you’ve had a recent oil spill, you’ll need a full SPCC Plan certified by a licensed Professional Engineer. These plans are more detailed, more technical, and must follow specific requirements under federal law. This is where having someone like RMA in your corner can make a big difference.

Still not sure which category you fall into? Don’t worry, we help folks figure this out every day. Reach out here and we’ll walk you through it.

A Quick Note on State Spill Plan Regulations & PE Certifications

The USEPA says that states can elect to not allow any self-certified plans, meaning states can decide on their own that all SPCC Plans need a PE certification. If you want proof, check out the last paragraph on this page.

As expected, when you delegate authority, that authority is often used. For example, the State of Kentucky's PE board says that all SPCC Plans in Kentucky need a PE licensed in Kentucky, no matter what. This isn't a critique one way or the other, you do you Kentucky, I'm just illustrating that some states have requirements around SPCC Plans that you need to consider, so check! Even if you're a Tier I facility, you might not be able to self-certify your SPCC Plan.

Speaking of states, it's important to call out that states can have rules and regs of their own that could mimic, mirror, copy, whatever, SPCC-styled regulations, but just at a state level. I'm specifically talking about requirements like a PPC Plan in Pennsylvania, PIPPs in Michigan, DPCC Plans in New Jersey, or SPC Plans in Louisiana.

None of these are SPCC Plans, but they're close. It's vitally important to understand you may need an SPCC Plan (federal requirement) and a state-level plan as well. Sometimes you can use one plan in place of both, but often facilities will have several different types of documents on-site.

What Kinds of Oils Are Covered Under SPCC Regulations?

Make no mistake: SPCC plans are for oils and petroleum products only. They aren't for hazardous chemicals, they aren't for things like diesel exhaust fluid (DEF) or antifreeze -they are just for oil!

The state-level requirements we just explained could touch on more materials, but with federal SPCC considerations, it's just oil.

Okay, that's all well and good, but here’s one of the most common (and most misunderstood) questions we get: “What exactly counts as oil?”

You might assume SPCC Plans are just for things like motor oil or diesel, and you'd be wrong! The EPA’s definition of “oil” is much, much broader. If you store it in large enough quantities, and it can make a mess if spilled, there’s a good chance it falls under this rule.

Here’s what IS covered:

• Petroleum products like diesel, gasoline, kerosene, lubricants, jet fuel, motor oil, hydraulic oil, transmission fluid… the list goes on.
• Synthetic oils include many modern lubricants and hydraulic fluids, all of which are included.
• Animal fats and vegetable oils are absolutely included. Yes, even cooking oil can trigger SPCC requirements if you’ve got over 1,320-gallons of it!
• Used oil is included, because it's still oil! Just because it’s spent doesn’t mean it’s exempt. In fact, it’s often treated even more carefully. Now, if the oil is mixed with other material, like water, it's a hazardous waste (and we would call that a "waste oil"). In that case, no, hazardous waste is not included. However, if you're storing a lot of hazardous waste, there could be other regulations at play worth reviewing.
• Fuel oils like what you might use to heat buildings or power backup generators are also included.
• Any type of oil you can name, it's included.

If it’s an oily liquid and can reasonably be expected to flow across the ground or into water if spilled... it’s probably included.

How Do I Get an SPCC Plan?

If you’ve realized you need an SPCC Plan, the next question is usually: “How do I actually get one?” The good news? This doesn’t have to be hard or expensive, especially if you get help from folks who do this all the time (that’s us).

• Tier I: You can do this yourself if you store under 10,000 gallons total and no container is over 5,000 gallons. DIY'er beware! If you put your plan together and it's not done well, you aren't going to get a participation trophy. Don't attempt this unless you can put it together and make a coherent plan. Even though it’s allowed by the federal government, many folks still choose to hire a pro - it’s not expensive, and you’ll know your plan can stand up to an inspection.

• Tier II: You can still technically do it yourself, but at this level (larger tanks, still under 10,000 gallons total), we really recommend using a professional. The requirements are more involved, and it’s easy to miss something. You cannot use the free plan linked above so you're working on something from scratch.

• Full PE-Certified: If you’re over 10,000 gallons or have had a spill, your plan must be developed by a professional and certified by a licensed Professional Engineer (PE). This one has to be done by the pros, there’s no DIY option here, unless you yourself are a PE!

Still unsure what category you’re in? That’s where we come in – reach out.

How Much Does It Cost to Get an SPCC Plan?

It depends on the type of plan, and obviously whether you’re doing it yourself or hiring a professional.

• Tier I or Tier II plans can be written in-house if you qualify. So yes, technically, it could cost you nothing. But many companies still bring in a pro to make sure the plan is complete, defensible, and won’t fall apart during an inspection. A Tier I plan might take a few hours of your time, a Tier II plan could be more time-intensive since there are no templates out there to use.

• Full PE-Certified plans are required for facilities with over 10,000 gallons of oil (or a spill history). These must be done by an expert and certified by a licensed Professional Engineer, so there’s no DIY option here.

If you go the professional route (and most facilities do), here’s what to expect:

• Tier I or II: $2,500–$7,500+ depending on complexity, location, and turnaround time. Generally cheaper, but not always. It just depends!
• PE-Certified: $4,000–$15,000+ depending on complexity, location, and turnaround time. Again usually more expensive, but it all depends!

At RMA, we can also sometimes develop SPCC Plans remotely, which keeps costs down and turnaround times fast, without sacrificing quality. And if you have multiple sites, we often offer bundled pricing. You can read more about how remote SPCC development works here and the cost of remote SPCC plans here.

If you're not sure what you need or what it’ll cost, just ask us. We’ll give you a straight answer.

Is Outsourced SPCC Plan Development Worth the Cost?

Absolutely. Here’s why:

• EPA fines for not having a required SPCC Plan can reach $68,445 per day per violation. So if you did one thing wrong for six months and you caused a big problem and they really want to throw the book at you, you're looking at one violation times 180 days times $68,445. That's... about 12.3 million dollars. You still think that $10,000 SPCC plan is too expensive?
• A single spill (even a small one) can cost thousands to clean up, especially if oil hits a storm drain or waterway. If you have a spill, you will be required to show your SPCC Plan, and if you don't have one, get out your wallet which hopefully has $12,000,000 in it!
• Having a real, working plan helps you avoid delays, business disruptions, and reputational damage. It keeps you out of trouble if you have a spill. It saves you money in an emergency like insurance. Sure, buying an SPCC Plan might cost a few thousand bucks, but, it's far, FAR cheaper than a non-compliance violation.

We've had clients come to us after an enforcement visit or a spill, and let’s just say... those situations are always more expensive and stressful than just getting the plan done right in the first place.

How Long Does it Take to Get an SPCC Plan?

If you’re doing it yourself, it takes as long as it takes. Some people put their head down and knock it out in a week, others spend months second-guessing themselves. It really depends on your familiarity with the regulations, the plan you're putting together, and how organized your site is.

If you’re hiring a professional, it really depends on two main things: how complex your facility is, and how available your consultant is. A rush job can sometimes be completed in a few days, but most full-service SPCC Plans (especially ones that require a site visit) take about a month from scheduling to final delivery. Some can get done faster, other's slower. All depends.

If you're eligible for a remote SPCC Plan, you're in luck. These can often be completed in under a month, especially if you have good site info ready to go. It’s faster, often cheaper, and still gets you a fully compliant, inspector-ready plan.

If time is a concern, contact us and we’ll give you an honest estimate based on your specific site.

What You Actually Have to Do With Your SPCC Plan

Okay, you've got your SPCC Plan, all good, right? Here’s the part that a lot of people overlook: it’s not enough to have an SPCC Plan, it has to be active, accessible, and regularly used.

Keep It On-Site and Accessible

Your SPCC Plan must be physically kept at your facility. It can’t be locked away in a filing cabinet no one touches, or stored on a Dropbox only the regional manager can access.

It should be accessible to all staff who need to use it and available immediately during an inspection. EPA inspectors will expect to see it on hand, and having it readily available demonstrates that you’re taking compliance seriously.

Use It During a Spill

If a spill happens, your SPCC Plan isn’t just a fancy document - it’s your emergency playbook. The plan outlines exactly what your team should do, who to call, what steps to take, and how to report the incident. In a high-stress moment, having a clear, practiced plan can prevent panic and major environmental damage.

Perform Monthly Inspections

One of the core requirements of an SPCC Plan is performing monthly inspections of your oil storage areas and any secondary containment. These inspections help you catch leaks, corrosion, or other issues before they turn into disasters. You’ll want to look for things like visible signs of wear on tanks, improperly sealed drums, or signs that containment systems aren't functioning as intended. And yes, you need to document these inspections.

Read: The Top 10 Things To Do During Your SPCC Plan Monthly Inspections

Update It As Needed If Things Change

If anything significant changes at your facility - like adding or moving tanks, changing staff responsibilities, updating emergency contacts, or modifying containment systems - your SPCC Plan needs to be updated right away. The EPA requires your plan to reflect your current site conditions, not how things looked years ago.

Do an Annual Review

Even if nothing has changed at your site, you have to sit down at least once a year and walk through your SPCC Plan. Does your site map still look right? Are all the emergency contacts up to date? Has your team been trained recently? An annual review helps keep your plan relevant, and it shows inspectors that you’re on top of it.

Conduct a Full Review Every 5 Years

The EPA requires that SPCC Plans be fully reviewed and updated at least once every five years. This is your opportunity to correct inaccuracies, update facility changes, and refine your procedures. If there’s been a spill or a change to oil storage, you need to update it sooner. This five-year window isn’t optional: fail to follow it, and you’re out of compliance.

Provide Annual Training for Your Staff

Everyone who works with or around oil at your facility should receive SPCC training once a year, at minimum. That training should go beyond a PowerPoint deck, it should include hands-on instruction where staff know what to do in the event of a spill, how to inspect equipment, and where the SPCC Plan is located. If you bring in new staff or revise your plan, you’ll need to provide additional training. A common practice is a "train the trainer approach" where one person gets a formal training (online, classroom, etc.) and then turns around and trains the staff internally. Cost effective and shows you're staying on top of things! Luckily, these days SPCC training is available online and it doesn't cost much!

Keep Good Records

Documentation is your friend. Keep records of:

• Every inspection you complete
• Every training session you hold
• Any spill responses and follow-up actions
• Any changes made to your SPCC Plan

If you ever get inspected (or have to defend your response to a spill), those records could save you from major penalties.

Actually Use the Plan

It might sound obvious, but it’s worth repeating: your SPCC Plan is meant to be used. That means following its procedures, referencing it during emergencies, and treating it as an active part of your environmental program. Not just a check-the-box document to sit on a shelf.

Is Anything New with SPCC Plans in 2025?

Yeah, absolutely! Here are some of the biggest things we're discussing with our clients this year.

You're More and More Visible

Every day the public is more aware of the world around them. People flying drones, kayaking down industrial rivers, motivated citizens, environmental groups, annoyed neighbors, competitors... you name it. There are a million ways to figure out who you are, where you’re operating, and those big oil tanks outside? Yeah, they’re very easy to spot on Google Maps. I cannot stress enough that flying under the radar is harder and harder to do.

Secondary Containment for Everything, Even the Small Stuff

The regulations require you to provide secondary containment for all regulated tanks. That means anything 55 gallons and up. I know what you're thinking: no. No, we're not putting that stuff in containment, we move the drums around, the totes come and go as we need them, we don't want to do that - we can't do that!

Turns out you can, you have to, and it's a requirement. Actually always has been, it's just the EPA has historically provided some wiggle room with smaller containers - at least based on our experience and our customers.

Think of it this way - I don't want to pay my taxes either, but I'm also afraid of being audited by the IRS. If you want to pick and choose which SPCC rules to follow, expect the 5th degree if you get inspected. Secondary containment is readily available and it's a requirement. In fact, you can buy secondary containment on Amazon. Just to be transparent, the following are affiliate links, and we do earn a few bucks if you buy one after clicking the link.

The days of saying "our drums in the garage don't need containment" don't cut it anymore. Something like these mobile spill dollies used to generally be good enough, but we're seeing EPA inspections requiring clients to get dedicated secondary containment for drums and totes no matter what. You could use a dedicated spill pallet for drums, but if they're mobile, that probably won't work. So if you need the drums to be mobile, you could get a mobile secondary containment drum (although your guess is as good as mine how you get a full drum in or out of there) but logistically, does that work for you?

There are various options for IBC totes as well. You can get your secondary containment for totes in either black or yellow! So many choices!

Point is, there are options, and the regulations flat out say secondary containment is required for all ASTs. These secondary containment products do exist, they are widely available, and you can even get them Prime, maybe not by 8am tomorrow morning, but pretty quickly! These items are low-hanging fruit during inspections and can cost you a few thousand bucks in violations. Plus, inspectors will require you to get them anyway, so you're paying for it one way or another.

Training Is Widely Available, and Training Certs Matter

You can't say "I watched an SPCC video on YouTube" and pretend it counts as training. Regulators want to see proof of training. They want documented third-party completion certifications that show you took, watched, or attended something. They might even check to verify it (we’ve been asked)!

Taking training online costs a few hundred bucks depending on who’s getting trained, and it’s way cheaper than paying for a violation, because you’ll be required to take training anyway. Check out our online SPCC training here!

AI Plans Are Pretty Useless

We've started to see it in action! AI-generated SPCC Plans that are... something else. In our opinion, they're not dependable. They generally cover the basics, but in the real world, they don’t give you the coverage you need when it really counts.

They often miss elements or simply echo back what the user wants to hear, not what the regulations actually say. From what we’ve seen, and from what we’ve helped clients recover from, these AI SPCC Plans generally miss the mark and should not be relied on.

That’s not to say the tech isn’t coming. In fact, there’s a big (and slightly scary) future where a lot of compliance documentation could be automated. But we’re not there yet. I’m not out of a job... yet!

Let’s Make SPCC Easy

Now that you understand what an SPCC plan requires, remember that failing to comply can lead to severe penalties. This isn't scare tactics, but we’re not going to sugarcoat it either. These are laws to follow just like anything else.

If you've felt unsure about SPCC Plans, how they apply, or your operation's compliance, your next step is to check where you stand. And if you can't figure that out on your own, reach out. At RMA, we’ve helped hundreds of companies through this process.

We know SPCC Plans can feel overwhelming. That’s exactly why we exist. At RMA, we’ve helped thousands of facilities across the U.S. stay compliant and avoid costly surprises.

Let us help you do it right - without the stress. Contact us today.

Whether you're starting fresh, updating an old plan, or just need help understanding your requirements, we're here to make it simple.