How to Compare SPCC Plan Proposals for a New Jersey Facility Before You Sign
You've got a couple of SPCC plan proposals in front of you and they don't look anything alike. The prices are far apart, one reads like a two-line email while another runs several pages, and nothing in either one explains why. An SPCC plan isn't something most facility managers buy often, so it's hard to know which proposal gets you a plan that holds up when an inspector shows up.
This article covers the six red flags we see most often in SPCC plan proposals for New Jersey facilities: no site visit, a price that assumes a generic template, no capacity verification or containment calculations, PE certification by someone who never sees the site, no discussion of integrity testing, and nothing said about amendments. If you'd like a second set of eyes on a proposal you're weighing, you're welcome to reach out to RMA, even if you end up hiring someone else.
Table of Contents
TL;DR
Six things should make you pause on an SPCC plan proposal: no site visit, a flat price that assumes a template, no mention of verifying capacity or calculating containment, a PE who never sees the site, nothing about integrity testing, and no plan for amendments. A good proposal names who examines the site, who certifies the plan, what drives the price, and how future changes and the five-year review get handled. In New Jersey, it should also say whether DPCC and DCR plans might apply to your facility, since an SPCC plan doesn't replace them.
What Should a Good SPCC Plan Proposal Include?
An SPCC plan is the written oil spill prevention plan required under 40 CFR Part 112 for facilities that store more than 1,320 gallons of oil aboveground and could reasonably be expected to reach navigable waters. In New Jersey, EPA Region 2 enforces it.
A good proposal reads like a scope of work. It tells you what the firm understood about your facility, what it's assuming, who will examine the site, who will certify the plan, what you'll receive, what's left out, how long it takes, and what it costs. When something is missing, the gap usually shows up in one of six places. The table gives the short version, and the sections after it explain each one. Our article on top SPCC plan violations and fines shows how these gaps turn into citations.
| Red flag |
What a good proposal says instead |
| No site visit |
Names who examines the facility and how, in person or through a described remote method |
| Flat price that assumes a template |
Ties the price to your capacity, container count, containment, and certification needs |
| No capacity verification or containment calculations |
Confirms container capacities and documents containment sizing in the plan |
| PE who never sees the site |
Names the PE, explains how the PE or the PE's agent examines the facility, and builds review into the price |
| No integrity testing discussion |
Sets an inspection and testing program tied to an industry standard and says whether testing is in scope |
| Nothing about amendments |
Explains how changes, the five-year review, and PE recertification get handled and by whom |
Red Flag 1: Why Is an SPCC Plan Proposal With No Site Visit a Problem?
An SPCC plan is supposed to describe your tanks, piping, transfer areas, drainage, and the path a spill would take to reach water. None of that gets written well from a phone call and a list of tank sizes. When a proposal never mentions a site visit, the firm is working from what you tell it or from a template, and either way the plan is only as accurate as your memory of the facility.
For a plan that needs a Professional Engineer's certification, the rule goes further. Before the PE certifies, the PE or an agent of the PE has to visit and examine the facility. A smaller qualified facility can self-certify its plan, so the PE requirement doesn't apply the same way, but the plan still has to match what's on your site. Our article on the different types of SPCC plans explains which category you're likely in.
Remote plan development isn't automatically a red flag. Some facilities are simple enough that a firm can work from photos, video, a site diagram, and detailed conversations with your staff. If a proposal is remote, though, it should say exactly how the facility gets examined, who does that, and what happens if something turns up that the remote review missed. We cover those questions in how remote SPCC development works and whether online SPCC plans are legit.
Red Flag 2: What Does a Generic Template Price Mean for Your SPCC Plan Cost?
A low price isn't a red flag on its own. A low price with no scope behind it is. If a proposal quotes a flat number without asking how many containers you have, how much oil-filled equipment is on site, or whether you've got truck loading areas, the number rests on an assumption that your facility looks like everyone else's. Plans built that way tend to be templates with your company name and tank list dropped in, and that's the kind of plan that gets cited when an inspector compares the document to the site. The same problem shows up with software-generated plans, which we tested in can ChatGPT or AI write an SPCC plan.
What moves the price of a real plan is the facility itself. Total storage capacity, the number and type of containers, oil-filled equipment, how secondary containment gets evaluated, whether there's piping or truck loading, whether a PE certification is needed, and how the site gets examined all play a part. SPCC plans generally run from about $2,500 to $15,000. Our SPCC plan costs article breaks down what each factor adds.
A good proposal explains what's in the price, what isn't, and what would change it. Our SPCC pricing calculator below gives you a ballpark for RMA's help with your own facility, which also gives you something to measure other proposals against.
Red Flag 3: Why Does a Proposal Need SPCC Capacity Verification and Containment Calculations?
Every SPCC decision starts with a number: how much oil you can store. The rule counts capacity, not what's in the tank today, and it adds up every aboveground container of 55 gallons or more. Transformers and other oil-filled equipment count, vegetable oils count, and propane doesn't. If a proposal never mentions verifying capacity, the totals are probably coming from an old plan or a quick estimate, and a wrong total can change which type of plan you need.
Containment is the second half. For bulk storage containers, secondary containment has to hold the entire capacity of the largest container plus enough freeboard for rain, and truck loading and unloading areas have their own requirements. The sizing is arithmetic, and the plan should show it. A proposal that says only that a containment evaluation is included, without saying calculations will be done and documented, leaves you guessing whether your dike or berm really works. Our article on how big your SPCC oil spill containment needs to be walks through the math, and the most overlooked SPCC requirements covers the spots where plans tend to go wrong.
Red Flag 4: What Should You Know About PE Certification of an SPCC Plan?
The PE certification is what makes a full SPCC plan effective under the rule. By certifying, the engineer attests that he or she is familiar with Part 112, that the PE or an agent has visited and examined the facility, that the plan follows good engineering practice, that the procedures for required inspections and testing are established, and that the plan is adequate for the facility.
The red flag is a PE seal with no real connection to your site. Watch for proposals that don't name the engineer, don't say how the PE or the PE's agent examines the facility, or treat certification as a rubber stamp at the end. A good proposal names the engineer or the engineering firm, says who visits, and confirms the PE reviews the plan before it's final, with any changes the PE requires built into the price. Our article on professional engineers and SPCC plan requirements goes deeper.
Does the PE Have to Work for the Consulting Firm?
No. Some consulting firms have a PE on staff, and others work with a trusted outside PE. Either arrangement can produce a sound plan. The test is whether a licensed PE actually reviews and approves the plan, and whether the proposal tells you who that is. It's also reasonable to ask whether the PE holds a New Jersey license, since you'd want the engineer certifying a New Jersey facility's plan to be properly licensed to do it.
Red Flag 5: Why Does SPCC Integrity Testing Belong in the Proposal?
Integrity testing is the requirement proposals skip most often, partly because it sounds like a separate job. The rule says to test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs, in accordance with industry standards, and EPA's guidance applies it to containers of 55 gallons or more. The rule calls for combining visual inspection with another technique, such as hydrostatic, radiographic, ultrasonic, or acoustic emission testing, along with frequent checks of the container exterior, supports, and foundations.
A proposal that says nothing about integrity testing usually produces a plan that says nothing useful about it either. A plan that describes tank inspections without naming an industry standard, such as STI SP001 for shop-built tanks or API 653 for field-erected tanks, leaves a gap an inspector can write up. A good proposal says the plan will set the inspection and testing program based on each container's size, configuration, and design, tie it to a recognized standard, and state whether the testing itself is in scope, because writing the program and performing the tests are usually different jobs with different people.
Our list of the top 10 things to do during monthly SPCC inspections is a good place to start, and our online training library covers training for the people doing the walkthroughs.
Red Flag 6: How Should an SPCC Proposal Handle Amendments and Five-Year Reviews?
Your facility will change. You'll add a tank, retire another, swap a container, change what you store, or move a loading area. Under the rule, a change in design, construction, operation, or maintenance that affects your potential for a discharge calls for a technical amendment. It has to be prepared within six months of the change and implemented as soon as possible, and no later than six months after it's prepared. For a PE-certified plan, the PE has to certify technical amendments. Simple changes like a new phone number are administrative and don't need PE certification.
Separately, the plan has to be reviewed at least once every five years, with the review documented even when nothing changes. If the review turns up field-proven technology that would significantly reduce the likelihood of a discharge, the plan has to be amended within six months. Our post on five-year SPCC plan reviews explains how the review differs from an amendment.
The red flag is a proposal that stops at delivery. It doesn't say what you get in editable form, who you call when you add a tank, whether you're expected to keep using the same firm, or how future changes get scoped. A good proposal answers those questions up front and says how it handles the five-year review.
One more flag if you're shopping because an existing plan is out of date: be skeptical of anyone who offers a quick update without seeing the site. An aging plan often needs to be rebuilt so the firm signing it can stand behind what's in it. We explain our thinking in can I get my SPCC plan updated.
What New Jersey Requirements Should an SPCC Plan Proposal Address?
New Jersey adds layers that a federal-only proposal can miss. The federal plan under Part 112 is enforced here by EPA Region 2. The state side runs through the Spill Compensation and Control Act, known as the Spill Act, and NJDEP's discharge rules at N.J.A.C. 7:1E. The Spill Act holds the party responsible for a discharge liable for cleanup costs, and it covers hazardous substances beyond oil.
What About DPCC and DCR Plans?
Facilities that qualify as major facilities under N.J.A.C. 7:1E have to prepare and submit a Discharge Prevention, Containment and Countermeasure plan (DPCC) and a Discharge Cleanup and Removal plan (DCR) to NJDEP. Whether your facility counts as a major facility depends on how much you store and what you store, so check the rule against your own inventory. A DPCC and DCR package is a separate set of documents reviewed by a different agency, and an SPCC plan doesn't take its place. NJDEP has also been revising these rules, so confirm current requirements instead of relying on older guidance. A proposal for a New Jersey facility with significant storage should say whether the firm screened for major facility status.
Underground tanks are another overlap. Completely buried tanks that are regulated under underground storage tank rules, which in New Jersey means N.J.A.C. 7:14B, are generally exempt from the federal SPCC rule, but they still belong on the facility diagram. Our article on SPCC plans in New Jersey covers the state specifics, and who enforces SPCC plans explains which agencies you might hear from.
How Can RMA Help You Evaluate an SPCC Plan Proposal?
If you're comparing proposals and something doesn't sit right, we're glad to talk it through. RMA is a family-run environmental consulting firm based in New Jersey, and we write SPCC plans for facilities across the country. Where the rule calls for it, a licensed PE reviews and approves the plan before it's final. Tell us about your facility and we'll explain how we'd approach it, how the site gets examined, who reviews and certifies the plan, and what the price covers.
If you're still sizing up what to expect from the process, our article on what it's like to hire an SPCC plan consultant walks through it. When you're ready, you can call us at 888-RMA-0230, send a message, or fill out the form on our website, and you can contact RMA with no pressure and no obligation.
