Essentials of Spill Prevention Control and Countermeasure Planning
Spills of oil and hazardous substances can cause serious harm to the environment, public health, and property. To prevent such incidents, the United States Environmental Protection Agency (EPA) requires certain facilities to prepare and implement a Spill Prevention, Control, and Countermeasure (SPCC) plan. But who exactly needs an SPCC? This post explains the key criteria, practical examples, and important details to help facility owners and operators understand when an SPCC plan is necessary.
What Is an SPCC Plan?
An SPCC plan is a written document that outlines how a facility prevents oil spills, controls potential releases, and responds to spills if they occur. The goal is to protect navigable waters and shorelines from oil contamination. The plan includes:
Facility description and layout
Oil storage locations and quantities
Spill prevention measures such as secondary containment
Procedures for inspections and maintenance
Emergency response actions
The EPA requires facilities that meet certain criteria to develop and implement an SPCC plan, which must be certified by a professional engineer or self-certified depending on the facility size.
Who Needs an SPCC Plan?
The EPA’s SPCC rule applies to non-transportation-related facilities that store oil and could reasonably discharge oil into navigable waters or adjoining shorelines. The main factors determining the need for an SPCC plan are:
Oil Storage Capacity
Facilities must have an aggregate aboveground oil storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons. This includes containers such as:
Tanks
Drums
Containers
Oil-filled equipment like transformers or hydraulic systems
For example, a farm with several aboveground diesel tanks totaling 1,500 gallons must have an SPCC plan, while a small workshop with a 500-gallon tank does not.
Potential to Discharge Oil
The facility must have a reasonable expectation that an oil discharge could reach navigable waters or shorelines. This depends on:
Proximity to water bodies such as rivers, lakes, or coastal areas
Drainage patterns and stormwater flow
Past spill history or known vulnerabilities
A facility located near a river with no barriers or containment is more likely to require an SPCC plan than one far from water or with effective containment.
Types of Oil Covered
The SPCC rule covers a broad range of oils, including:
Crude oil
Fuel oils like diesel and gasoline
Lubricants
Hydraulic oils
Animal fats and vegetable oils
Facilities storing any of these oils in quantities above the thresholds must evaluate their SPCC obligations.
Examples of Facilities That Need an SPCC Plan
Gas stations with multiple underground and aboveground fuel tanks
Manufacturing plants using large volumes of lubricants or hydraulic oils
Agricultural operations storing diesel fuel for machinery
Electric utilities with oil-filled transformers and capacitors
Oil production and storage facilities
Each facility must assess its oil storage and spill risk to determine if an SPCC plan is required.
What Does Preparing an SPCC Plan Involve?
Developing an SPCC plan requires a detailed review of the facility’s oil storage and handling practices. Key steps include:
Inventory of oil containers and total capacity
Site drainage and topography analysis to identify spill pathways
Design of secondary containment such as dikes, berms, or curbs
Spill prevention procedures including regular inspections and maintenance
Employee training on spill prevention and response
Emergency response planning with notification procedures and cleanup methods
The plan must be reviewed and updated every five years or whenever significant changes occur.
Common Misconceptions About SPCC Plans
Only large oil companies need an SPCC plan
Many small and medium-sized facilities also meet the criteria due to aggregate storage capacity or proximity to water.
Underground tanks are exempt
Underground storage tanks are regulated under different rules but still count toward total oil capacity for SPCC purposes.
SPCC plans are only for oil spills on land
The plan’s focus is preventing oil from reaching navigable waters, so water protection is central.
Self-certification is not allowed
Facilities with less than 10,000 gallons total capacity and no spills in the past three years may self-certify their plans.
Benefits of Having an SPCC Plan
Beyond regulatory compliance, an SPCC plan helps facilities:
Reduce the risk of costly environmental damage and cleanup
Protect local ecosystems and water quality
Avoid fines and legal penalties
Improve operational safety and employee awareness
Prepare for emergencies with clear response steps
Investing time in SPCC planning can save money and reputation in the long run.
What Happens If You Don’t Have an SPCC Plan When Required?
Facilities that fail to prepare and implement an SPCC plan face:
EPA enforcement actions including fines up to tens of thousands of dollars per day
Increased liability for environmental damage
Higher cleanup costs and operational disruptions
Negative public and community relations
The EPA conducts inspections and may respond to spill incidents by reviewing SPCC compliance.
How to Get Started With Your SPCC Plan
Assess your oil storage: List all containers and total capacity
Evaluate your site’s spill risk: Consider location and drainage
Consult EPA guidance: Review the SPCC rule and templates
Decide on plan certification: Engineer certification or self-certification
Develop your plan: Document prevention, control, and response measures
Train your staff: Ensure everyone knows their role in spill prevention
Review and update regularly: Keep the plan current with facility changes
Wolfpack Environmental Solutions can assist with your SPCC needs.
Contact Wolfpack Environmental Solutions (562) 231-7339 for any CUPA or DTSC compliance assistance.
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