What to Expect From Site Visit to Finished Oil Spill Plan, and Why Some Pennsylvania Facilities Wait Longer Than Others
If you store oil at a Pennsylvania facility and just learned you need an SPCC Plan, the first question is usually how soon you can have one. An SPCC Plan, short for Spill Prevention, Control, and Countermeasure Plan, is the written oil spill prevention plan EPA requires under 40 CFR Part 112 if your facility stores more than 1,320 gallons of oil aboveground (counting only containers of 55 gallons or more) or more than 42,000 gallons buried. If that's you, expect the process to take about one to eight weeks, with most of the plans we prepare landing in the two to five week range, and rush jobs finishing in under a week.
Below, we walk through the steps in developing a plan, what a rush job looks like, what slows projects down, how Professional Engineer certification changes the schedule, and what you can do to get yours done sooner. If you'd rather talk through your own situation at any point, you can reach out to RMA.
Table of Contents
TL;DR
Most SPCC plans take about two to five weeks from the first contact to a finished plan. The full range runs from under a week for a rush job to a couple of months when things stall. The schedule depends on how fast the site visit gets booked, how quickly you can answer questions about your oil storage and operations, how long your team takes to review the draft, and whether a Professional Engineer has to certify the plan. Having your oil inventory and a knowledgeable person ready is the best way to shorten it.
How Long Does an SPCC Plan Take in Pennsylvania?
A fair answer is one to eight weeks, which is a big range, and the reason is simple. The timeline depends less on the plan itself than on how smoothly information moves between your facility and the person writing it. Some facilities hand us every piece of information we need right out of the gate, and those plans go extremely fast, especially when the site is close and our schedules line up for a quick visit. Others need weeks of back and forth before the draft is even finished.
Here's how the common scenarios break down.
| Scenario |
Typical Timeline |
What Drives It |
| Rush project |
Under 1 week, often within the same business week |
Quick site visit, complete information on day one, and a higher price for dropping other work |
| Typical RMA plan |
2 to 5 weeks |
Normal scheduling, a round of follow-up questions, and time to review the draft |
| Larger or more complex facility |
Toward the longer end of the range |
Additional site visits, technical review, and Professional Engineer certification |
| Stalled project |
Several weeks to a couple of months |
Delayed site visit, missing operations details, or a slow internal review |
Most of the plans we do at RMA finish in two to five weeks, and that's a realistic expectation for a typical Pennsylvania facility. When a project runs past that, the plan work is rarely what's holding it up. More often we're waiting on a person, a piece of equipment information, or a final sign-off on the draft. We cover the general factors behind these numbers in our broader guide on how long an SPCC Plan takes, and this article focuses on what that looks like in practice for Pennsylvania facilities.
What Steps Go Into Developing an SPCC Plan?
Every SPCC Plan we prepare follows the same basic path, and knowing the steps makes it easier to see where the time goes. First comes the site inspection. We walk the facility, identify every oil container, and look at piping, loading and unloading areas, secondary containment, and the path water would take if a spill got loose. Second, we ask questions about your operations: how oil gets delivered and transferred, who does inspections, whether you've had spills, and how the equipment is used day to day.
Third, we develop the plan itself, including the facility diagram, the inspection and testing procedures, and the spill response sections. Last, we deliver the finished plan, train your staff on what it requires, explain what you're now responsible for, and send you off to put it to work. Initial SPCC training is free with a new RMA plan. If you want to see what ends up in the document, we break it down in our article on what goes into an SPCC Plan for a Pennsylvania facility.
Actual writing time is the smallest piece of the schedule in most projects. The calendar days go to scheduling the visit and collecting answers, which is why two facilities with nearly identical tanks can end up with very different timelines.
Can You Get an SPCC Plan Quickly if You're in a Hurry?
Yes. When a facility gives us what we need up front, the site is within reach, and our work schedules line up, we can finish a plan in under a week without any trouble. That usually means within the same business week, and sometimes within a day or two. The catch is that you'll pay for it. A rush job means we're dropping other work to focus on yours, and the price reflects that. For a sense of where standard pricing lands, our article on what an SPCC Plan costs lays out the ranges, and our SPCC pricing calculator gives you a facility-specific estimate.
Most rush requests come from one of a few places. A lender or insurance company asked for the plan. Someone just learned the facility needs one. Or the plan has been sitting on the to-do list for a while and a deadline finally showed up. If you're opening a new facility, the federal rule expects the plan to be prepared and in place before you begin operating, so build it into your startup schedule early. Construction approvals are a separate track that RMA doesn't handle, but we're glad to help you figure out what the construction phase needs and point you toward the right people while we handle the oil spill plan that comes with running the facility.
If you're not sure the rule applies to you at all, start with our guide on how to tell whether your facility needs an SPCC Plan, because a rush job makes the most sense once you know you need one. EPA's Region 3 office enforces the SPCC rule in Pennsylvania, so it's far better to settle the question before an inspector, lender, or insurer asks to see a plan.
What Slows Down an SPCC Plan Timeline?
When a project stretches into weeks and weeks, or crosses into a month or two, the cause is almost always on the information side, not the writing side. Three things account for most of it.
Site Visit Scheduling and Missing Operations Information
The first delay is simply getting on site. Conflicting schedules can push the visit back, and once we're there we often have follow-up questions about your processes and equipment. Maybe you need to check with maintenance, ask a supervisor, or track down specifications for a tank or a piece of oil-filled equipment. We can't finish the document until we have those answers, and collecting them sometimes takes longer than writing the plan.
Client Review of the Draft
Once we deliver the plan, reviewing it is up to you. Some clients tell us they hired us because they don't want to read it, and if we think it's good, they're happy. Others want to read it from front to back, run it past management, and send comments before anything is finalized. That's a reasonable thing to do, and the large majority of reviewers come back with "looks great, please finalize it." Every so often a client sits on the draft for a couple of weeks or even a couple of months. In those cases we haven't stopped working. The plan is just waiting on the client.
Larger or More Complicated Facilities
Facilities with many containers, complex piping, or several operating areas can need additional site visits and more technical review, which adds real time. They're also the facilities most likely to need Professional Engineer certification, which gets its own section below.
How Does PE Certification Affect SPCC Plan Timing in Pennsylvania?
Whether a Professional Engineer (PE) has to certify your plan depends on the size and setup of your facility. Under the federal rule, a facility with 10,000 gallons or less of aboveground oil storage, no single container over 5,000 gallons, and a clean spill history can qualify for the self-certification path, where the owner signs the plan instead of an engineer. Facilities that don't qualify, or that use certain alternative measures, generally need a licensed PE to review and certify the plan. Our article on which type of SPCC Plan your Pennsylvania facility needs walks through how to sort out where you land.
When PE certification is required, it adds time because one more person has to review the work. We don't give a fixed number of days for the review because it depends on the facility, but it's the main reason PE-certified plans tend to sit at the longer end of the range. To see what the engineer is doing in that step, read what a PE does when certifying a Pennsylvania SPCC Plan, and for the licensing question, see whether the engineer needs a Pennsylvania license.
How Can You Speed Up Your SPCC Plan in Pennsylvania?
The best thing you can do is be prepared. Before the site visit, pull together what you can on your oil storage, and make sure someone who knows the operation will be available to answer questions. A short list covers most of it:
- Every container that holds oil, with its size, what it holds, and where it sits, including drums, totes, and oil-filled equipment.
- Details on piping, transfer points, and loading or unloading areas.
- A knowledgeable person, such as a maintenance lead or facility manager, who can answer questions during and after the visit.
- Any past spill history and your current inspection practices.
- Time on someone's calendar to review the draft when it arrives.
If you're not sure how to count everything, our guide on how to inventory your oil tanks, drums, and equipment is a good place to start. We also put together a longer resource for environmental managers, the guide to speedy SPCC Plan development.
You can also write your own plan if your facility qualifies for self-certification and you're comfortable with the requirements. We cover the first question in can you self-certify your SPCC Plan in Pennsylvania and the second in how to write your own SPCC Plan. Writing it yourself costs you time instead of consulting fees, and you're taking on the responsibility of getting it right, so the choice comes down to how much of both you want to spend. Whichever way you go, your staff will need training once the plan is in place, and our online training library is one option.
How Does RMA Help With Your Pennsylvania SPCC Plan Timeline?
If you'd rather have your plan professionally prepared, we handle the facility inspection, the plan development, and any PE certification that's needed through an outside engineer. We'll work around your schedule to get a completed plan in place without unnecessary delays, and we'll tell you up front if your facility looks like a two-week project or a two-month one. If you only need a second opinion on whether you can do this yourself, we're happy to say so.
There's no pressure and no obligation. You can call, email, or fill out the form on our website, and we'll talk through your oil storage and your timeline. When you're ready, contact us and we'll take it from there.
