A Section-by-Section Look at What Each Part of an SPCC Plan Is For, and What Makes It Work at a Pennsylvania Facility
An SPCC Plan is the written oil spill prevention plan that 40 CFR Part 112 requires for facilities storing enough oil. If you're responsible for one in Pennsylvania, you've probably flipped through a long binder and wondered what half of it is for. The plan follows a fairly fixed structure, and each part exists to answer one practical question about your site.
This post walks through a typical SPCC Plan section by section, covering what each part is for, what separates a useful one from filler, and where Pennsylvania's DEP storage tank rules fit around the federal plan. If you'd rather have someone look at your plan directly, you can reach out to RMA at any point.
Table of Contents
TL;DR
A federal SPCC Plan follows 40 CFR 112.7: facility description and diagram, container inventory, discharge predictions, secondary containment, transfer procedures, inspections and tests, security, training, response and notification, and sign-off by management and, for most facilities, a Professional Engineer. Each section answers a practical question, like where oil would go or who does what when it does. Pennsylvania doesn't replace the federal plan. DEP's storage tank program, and for larger facilities its Spill Prevention Response Plan, sit alongside it, and the SPCC Plan has to account for them.
How Is an SPCC Plan Organized, and What Does Each Section Do?
The federal rule at 40 CFR 112.7 sets the order most plans follow. You can use a different layout if it's equivalent and you add a section cross-referencing where each requirement lives, but most consultants keep the standard sequence because inspectors know where to look. In Pennsylvania, that inspector is from EPA Region 3. The plan also has to follow good engineering practice and carry management's full approval. Here's the structure at a glance for a typical onshore facility handling petroleum oils.
| Plan section |
Question it answers |
Main rule reference |
| Facility information and diagram |
What is on site, and where? |
40 CFR 112.7(a)(3) |
| Oil container inventory |
What oil do you store, and how much? |
112.7(a)(3)(i) |
| Discharge prediction |
If something fails, where does the oil go? |
112.7(b) |
| Secondary containment |
What keeps a spill from leaving? |
112.7(c), 112.8(c)(2) |
| Loading and unloading procedures |
How is oil moved safely? |
112.7(a)(3)(ii), 112.7(h), 112.8(d) |
| Inspections and testing |
How do you know the equipment is sound? |
112.7(e), 112.8(c)(6), 112.8(d)(4) |
| Security |
Who can reach the oil and the valves? |
112.7(g) |
| Personnel training |
Do the people on site know the plan? |
112.7(f) |
| Spill response and notification |
What happens in the first hour? |
112.7(a)(3)(iv) to (vi), (a)(4), (a)(5) |
| Certification and management approval |
Who stands behind the plan? |
112.3(d), 112.7, 112.6 |
Most plans open with the facility's name, address, owner or operator, what the site does, and how it sits in the landscape. That last piece ties the plan to the real world. It should say where the nearest storm drain, ditch, or stream is and which way the ground slopes toward it. The rule's applicability test is based on location alone, so dikes, tanks, and other manmade features can't be counted when deciding whether a spill could reach navigable waters.
The facility diagram is the core of this section. It has to mark the location and contents of each fixed oil container and the storage area for mobile or portable containers, along with transfer stations and connecting pipes. Exempt underground tanks get marked "exempt" rather than left off. A good diagram matches what someone sees walking the site, uses container labels that match the inventory, shows drainage paths, and gets redrawn when a tank moves.
How Does an SPCC Plan Inventory Oil Containers and Storage Capacity?
The plan has to give the type of oil in each fixed container and its storage capacity. For drums and totes, it can list each one or estimate the number, oil types, and sizes you'll typically have. Most plans use a table with one row per container, a tag that matches the diagram, the oil, the capacity, and how the container is built.
Capacity counts, not how full a container is. The federal threshold is more than 1,320 gallons aboveground, counting only containers of 55 gallons or more, or more than 42,000 gallons completely buried. Oil-filled equipment belongs in the inventory, and exclusions like permanently closed containers should be named so a reader can see what was left out. Totals also decide the plan type. Tier I qualified facilities have no single aboveground container over 5,000 gallons, Tier II qualified facilities have 10,000 gallons or less in total, and both need a clean discharge history. Our article on 55-gallon drums and SPCC plans covers a common counting question.
What Is the Discharge Prediction Section of an SPCC Plan?
This section answers a simple question: if it fails, where does the oil go? Where experience indicates a reasonable potential for equipment failure, such as loading and unloading equipment, tank overflow, rupture, or leakage, the rule asks for a prediction of the direction, rate of flow, and total quantity of oil that could be discharged from each type of major equipment failure.
A useful prediction is specific to the site. For a diesel tank filled from a truck, it describes a hose failure or overfill, estimates the pump rate and how long it would run before someone noticed, gives the resulting volume, and says which way the oil would flow and which drain or swale it would reach first. "A spill could reach the stormwater system" doesn't do that work. Detailed predictions let a reader check whether the containment and response steps that follow were built for failures that can realistically happen.
How Does the SPCC Plan Secondary Containment Section Work?
Secondary containment is the backstop when a primary container fails. For bulk storage tanks, the benchmark is containment for the entire capacity of the largest single container plus enough freeboard for precipitation, with walls and floors impervious enough to hold oil until cleanup. Dikes, curbs, and pits are the usual choices, and mobile or portable containers get the same treatment. Our guide on how big SPCC containment needs to be covers the sizing.
Drainage gets less attention than the walls. Diked areas should drain through manual open-and-closed valves, and flapper-type valves aren't allowed. Rainwater drained from a dike should be inspected first, with the bypass valve kept sealed closed otherwise and each drainage event recorded. Undiked areas where a spill could occur need drainage that leads to a catchment basin so the oil stays on site.
Where containment isn't practicable, the rule lets the plan say so, but it has to explain why, be certified by a Professional Engineer, include periodic container and piping testing, and add an oil spill contingency plan with a written commitment of manpower, equipment, and materials. Qualified oil-filled operational equipment has a separate alternative built on inspections, a contingency plan, and a clean discharge history. Both are exceptions, and a good plan treats them that way.
What Should SPCC Loading and Unloading Procedures Cover?
The rule asks for discharge prevention measures, including procedures for routine product handling like loading, unloading, and facility transfers. Employees and delivery drivers touch this section more than any other, so it should read like site instructions: who's present for a delivery, how the tank's available room is confirmed before filling, where hoses connect, where drip pans go, and what happens if someone has to walk away. Bulk containers also need at least one overfill device, such as a high level alarm, a pump cutoff, or direct communication between the gauger and the pumping station, and level sensors have to be tested regularly.
Facilities with a tank truck loading rack add items under 112.7(h): a quick drainage system or containment sized for the largest single compartment, barriers, interlocks, or wheel chocks that stop a vehicle from leaving before the hoses are disconnected, and a check of each truck's lowermost drain and outlets. Piping adds capped or blank-flanged idle connections and warnings to vehicles entering the site.
What Inspections and Testing Does an SPCC Plan Have to Describe?
Inspections and tests have to follow written procedures developed for the facility, and those procedures plus signed records stay with the SPCC Plan for three years. Records kept under normal business practices count, so an existing maintenance log can work. This section spells out what's inspected, how often, by whom, and where the record lives.
| Item |
What the rule asks for |
What the plan should say |
| Aboveground containers |
Integrity testing or inspection on a regular schedule and after material repairs, plus frequent outside checks and inspection of supports and foundations |
Test method, frequency, who's qualified, where comparison records are kept |
| Diked areas |
Prompt correction of visible leaks and removal of oil accumulations |
Who checks, how often, who drains |
| Aboveground valves and piping |
Regular inspection of flanges, joints, valves, supports, and catch pans |
Checklist and frequency |
| Buried piping |
Integrity and leak testing at installation, modification, relocation, or replacement |
What triggers a test |
| Overfill devices and level sensors |
Regular testing to confirm they work |
Test frequency and who performs it |
The rule leaves test type and frequency to industry standards that account for container size and design, such as those from the Steel Tank Institute and the American Petroleum Institute, so "inspect monthly" isn't enough on its own. Our guides on monthly SPCC inspections and overlooked SPCC requirements cover what facilities typically miss. In Pennsylvania, DEP certifies tank installers and inspectors under 25 Pa. Code Chapter 245, and its tank rules carry inspection expectations of their own, so check both when setting a schedule.
How Does an SPCC Plan Address Security of Oil Storage Areas?
Section 112.7(g) asks how you secure and control access to oil handling and storage areas, and it lists what to address: master flow and drain valves, starter controls on oil pumps, out-of-service and loading or unloading connections on pipelines, and security lighting that deters vandalism and helps someone spot a discharge. A useful section names the actual fence, locks, and lighting at the site and who holds the keys.
Security is also a requirement the plan may deviate from, as long as it states the reason and describes an alternative that gives equivalent environmental protection. That suits a small site where a locked valve and good lighting do more than a fence would.
What Does the SPCC Plan Personnel Training Section Have to Include?
The rule has three parts. Oil-handling personnel have to be trained in equipment operation and maintenance to prevent discharges, discharge procedure protocols, applicable pollution control laws, general facility operations, and the plan's contents. A person at each facility has to be designated as accountable for discharge prevention and report to management. And briefings for oil-handling personnel have to be held at least once a year, covering known discharges, failures, malfunctioning components, and new precautions.
A good section names the accountable person by role, says who counts as oil-handling personnel, and says where briefing records are kept. The rule doesn't spell out training records the way it does inspection records, so documenting attendance and topics is how you show it happened. Our posts on annual SPCC training and what SPCC training should include go further, and our online environmental training library saves you from building material from scratch.
What Goes Into SPCC Spill Response and Notification Procedures?
This section is written for the worst day on site, so the rule says the procedures have to be organized to be readily usable in an emergency, with supporting material in appendices. It covers countermeasures for discovery, response, and cleanup (what the facility can do and what a contractor would), disposal of recovered materials, and a contact list with phone numbers for the facility response coordinator, the National Response Center, cleanup contractors under agreement, and the agencies to notify. If anyone is in danger, getting people safe and calling emergency services comes before any procedure.
The plan also has to help whoever reports a discharge relay the facility's address and phone number, the date and time, the material, estimated quantities, the source, affected media, the cause, any injuries, actions underway, whether evacuation may be needed, and who else has been contacted. A one-page form near the phone covers it. Larger facilities that submit a Facility Response Plan under 112.20 follow that plan instead. Our article on the sheen rule explains when a spill becomes reportable.
Pennsylvania adds its own notification layer. Under 25 Pa. Code 245.305, the owner or operator of a storage tank system generally has to notify the appropriate DEP regional office as soon as practicable, and no later than 24 hours, after confirming a release. Facilities with more than 21,000 gallons of aboveground capacity also have to immediately notify the county emergency management agency, the Pennsylvania Emergency Management Agency, and DEP. The rule has thresholds and exceptions, so the plan should point to the requirement for each tank. Separately, a discharge to the waters the federal rule covers of more than 1,000 gallons, or more than 42 gallons in each of two events within twelve months, requires a written report to EPA's Regional Administrator within 60 days, copied to the state. A spill that leads to penalties or liability questions is a time to bring in an environmental attorney alongside your consultant.
How Do SPCC Plan Certification and Management Approval Work?
The plan carries two signatures that mean different things. The rule requires the full approval of management at a level of authority to commit the resources to implement the plan, which shows someone with budget authority stands behind it. The second is certification, which for most facilities comes from a licensed Professional Engineer who attests to knowing Part 112, having visited and examined the facility, preparing the plan under good engineering practice, establishing inspection and testing procedures, and finding the plan adequate for the facility.
| Plan type |
Who certifies |
Qualifying criteria |
| Tier I qualified facility |
Owner or operator self-certifies, and can start from EPA's Tier I template |
No single aboveground container over 5,000 gallons, and no single discharge over 1,000 gallons or two over 42 gallons within twelve months in the prior three years |
| Tier II qualified facility |
Owner or operator may self-certify, but certain sections, such as deviations, still need a Professional Engineer |
10,000 gallons or less aboveground in total, with the same discharge history |
| All other facilities |
A licensed Professional Engineer certifies under 112.3(d) |
Everything that doesn't qualify above |
Certification doesn't relieve the owner of implementing the plan. Technical amendments need PE certification too, and the plan has to be reviewed at least every five years, with a signed statement on whether it will be amended. Amendments are due within six months of a material change like commissioning or decommissioning containers. New facilities need the plan prepared and implemented before oil operations begin, and facilities attended four or more hours a day keep a complete copy on site. See our articles on professional engineers and SPCC requirements, types of SPCC plans, and five-year reviews.
How Does Pennsylvania's Storage Tank Program Fit Around an SPCC Plan?
The SPCC Plan is a federal document enforced by EPA Region 3 in Pennsylvania, and it sits beside a state program. DEP runs the storage tank program under the Storage Tank and Spill Prevention Act and 25 Pa. Code Chapter 245, which requires tank owners to register tanks within 30 days after installation or acquisition unless the tank is excluded. Whether yours needs registration depends on its size, type, and use, so check it against DEP's storage tank program. Section 112.7(j) is where the two meet: the plan has to discuss conformance with any applicable, more stringent state rules.
Facilities with more than 21,000 gallons of aggregate aboveground storage also prepare a Spill Prevention Response Plan (SPRP) for DEP, and some DEP water permits call for a Preparedness, Prevention and Contingency (PPC) Plan. These overlap with the SPCC Plan on containment, response, and contacts, and some facilities combine them. If a combined plan goes to DEP, DEP can review the SPCC portions, so think before merging, and keep tank counts consistent across documents.
Building or expanding a facility? Some new tanks need DEP installation permits and certified installers. We don't prepare construction-phase permits, but the SPCC Plan has to be in place before oil operations begin, and that's where we can help.
How Can RMA Help With Your Pennsylvania SPCC Plan?
We're a family-run firm based in New Jersey, and we write and review SPCC Plans for facilities across Pennsylvania and nationwide. Senior staff do the work, and we don't use AI to produce client deliverables. Whether you have a plan you want checked section by section or you're starting fresh, we'll tell you what we'd expect to see for your site, and if you don't need us, we'll say so. SPCC Plans typically run about $2,500 to $15,000, depending on the number of containers, whether PE certification is needed, and how involved the containment evaluation gets. Our cost guide and pricing calculator break it down, and our SPCC learning center is there if you'd rather keep going on your own.
There's no pressure and no obligation. Call 888-RMA-0230, email us, or reach out to RMA through the form on our website whenever it suits you.
