If your facility stores oil in any meaningful quantity, federal law requires you to have a Spill Prevention, Control, and Countermeasure plan. The regulation that governs it is 40 CFR Part 112. The questions we hear most often are some version of “what has to be in the plan?” and “is what we have actually compliant?”
This piece walks through what a complete SPCC plan must contain, what each section covers, and the data your facility has to provide for the plan to be defensible. For the broader question of who needs an SPCC plan and how the service works in California, see our SPCC plan development and certification services in California guide.
What a Plan Is and What It Must Cover
An SPCC plan is a written, facility-specific document that describes how your facility prevents oil discharges, contains them when they happen, and responds when containment fails. It is signed by either the facility owner (in limited cases) or a California-registered professional engineer (in most cases). It stays on site, available to inspectors and oil-handling personnel.
The plan must address every aspect of oil storage and handling at your facility. That includes fuel tanks for backup generators, waste oil storage, hydraulic and lubricating oil reservoirs in machining equipment, facility-owned transformers, drum storage, and any other container of 55 gallons or larger. Once your total aboveground oil storage exceeds 1,320 gallons, the regulation applies to all of it. Every container counted toward the threshold, including smaller ones, must be addressed in the plan.
The 14 Sections of a CDMS SPCC Plan
CDMS organizes PE-certified SPCC Plans into the following 14-section structure to address the applicable requirements of 40 CFR 112.7 and the facility-specific sections that follow it. Appendices typically add inspection logs, drawings, training records, and the Substantial Harm Checklist.
Section I: Introduction. Plan purpose, scope, regulatory basis, and a brief description of the facility. Sets the frame for everything that follows.
Section II: Facility Information. Owner and operator details, facility address, contact information for the qualified person responsible for the plan, location coordinates, and the general nature of operations.
Section III: Amendment of Plan. A record of every revision made to the plan since it was first written. The 5-year technical review and any earlier amendments (tank additions, ownership changes, spill events) get logged here with dates and a summary of what changed.
Section IV: Discharge Prevention Measures. How your facility prevents oil from being released in the first place. Loading procedures, drip pans, transfer protocols, leak detection, and the operational practices that reduce the likelihood of a release.
Section V: Discharge and Drainage Controls. Secondary containment around tanks and transfer areas. Containment must have enough capacity to hold the largest single container plus precipitation. This section also covers how drainage from containment areas is managed (manual valve operation, oil/water separators, sumps) and how rainwater is released.
Section VI: Bulk Storage Containers. Every tank, drum, and container of 55 gallons or larger gets listed here with capacity, construction material, contents, age, overfill prevention, and the integrity testing and inspection schedule that applies to it. This is the section where tank certification and SPCC compliance overlap directly: aboveground storage tank integrity testing is referenced as part of the inspection schedule. For more on integrity testing, see our hazardous waste tank certification guide.
Section VII: Facility Transfer Operations. How oil enters and leaves the facility. Loading and unloading procedures, transfer points, piping systems, valves, and the practices that prevent overfills and transfer-related releases.
Section VIII: Countermeasures and Spill Mitigation. What your facility does when a spill happens. Spill kit locations, response procedures, who responds first, how the incident is documented, and the chain of internal and external notifications required after a release.
Section IX: History of Releases. Documented spill history at the facility. Releases exceeding the federal reporting thresholds in the prior 12 months must be addressed. This is also one of the determinants of whether your facility qualifies for self-certification.
Section X: Prediction of Release. A reasoned analysis of where releases are most likely to occur at your facility and what direction the oil would flow if a release happened. This is the section that ties the plan to the actual layout of your site.
Section XI: Inspections, Tests, and Records. The inspection program. SPCC requires inspections and tests according to written procedures developed for the facility, with records signed and kept for at least three years. CDMS implements this through monthly visual inspections of containers and containment, annual comprehensive inspections, and STI-format logs as the inspection standard. For a complete breakdown of inspection frequencies and what inspectors look for, see our SPCC inspection requirements guide.
Section XII: Security. How the facility prevents unauthorized access to oil storage areas. Fencing, lighting, locks on valves, master flow control, and access procedures.
Section XIII: Personnel Training and Discharge Procedures. Who must be trained, what the training covers, when it happens, and how it is documented. Oil-handling personnel must be trained before they are assigned unsupervised oil-handling responsibilities, and discharge prevention briefings must be conducted at least annually.
Section XIV: Certification. The signature page. For PE-certified plans, the California-registered professional engineer signs and seals here. For self-certified plans (Tier I or Tier II qualified facilities only), the facility owner attests they are familiar with 40 CFR 112 and prepared the plan.
SPCC Plan Requirements Checklist
A defensible plan, ready for an inspector, has all of the following:
- [ ] All applicable requirements of 40 CFR 112 addressed with facility-specific content, not generic boilerplate (CDMS covers these across 14 plan sections)
- [ ] Tank and container inventory listing every storage unit 55 gallons or larger
- [ ] Secondary containment calculation for every storage area
- [ ] Facility diagram showing storage locations, transfer points, drainage paths, and spill response equipment
- [ ] Substantial Harm Checklist determination of whether a Facility Response Plan is required
- [ ] Inspection program set up, with monthly and annual logs in use
- [ ] Training records on file for all oil-handling personnel
- [ ] PE certification or, where applicable, owner self-certification
- [ ] Plan stored on site, accessible to inspectors and personnel
- [ ] Compliance calendar tracking the 5-year technical review
Not sure whether your existing SPCC plan covers all 14 sections? Call (925) 551-7300 or request a consultation. We can review your current plan against 40 CFR 112 and identify any gaps before an inspector does.
What the California Layer Adds
California facilities that store petroleum products aboveground are also subject to the Aboveground Petroleum Storage Act (APSA), administered by your local CUPA (which may be a county environmental health department, fire department, or another local agency depending on jurisdiction). APSA runs alongside SPCC, not instead of it. Federal SPCC covers all oils: petroleum, vegetable, animal fat, synthetic. APSA covers petroleum only.
For California facilities, the SPCC plan document itself stays on site. It is not uploaded to CERS, the state’s online environmental reporting portal. However, APSA-specific information, including the Tank Facility Statement, is submitted through CERS. The routing matters: facilities that try to upload the full SPCC plan to CERS are doing something the system does not require, and facilities that fail to submit the APSA Tank Facility Statement get cited by CUPA.
The Title 19 update to the APSA program regulations took effect December 17, 2024, changing how California regulates aboveground petroleum storage. If your existing plan predates that update, the California layer of your compliance may need review even if the federal SPCC document is current.
What Your Facility Has to Provide
For the plan to be specific to your facility rather than a template with your name on it, our team needs the underlying data. When we walk a facility for SPCC development, the inventory we build includes age and construction material of every tank, dimensions, contents, overfill prevention method, and whether each tank is aboveground or underground. We measure every secondary containment and document drainage methods. We photograph every storage area. We log connecting piping, transfer stations, and spill response equipment locations.
The most common issue we see during SPCC reviews is plans written from a template without this level of site-specific detail. A plan with the wrong tank inventory, missing transfer points, or an outdated facility diagram is not defensible when an inspector arrives.
Beyond the Document
A plan on the shelf is not compliance. The regulation requires that the plan be implemented. Inspections happen on schedule. Training is current. Inspection logs exist and are filled out. Spill response procedures match what the plan says. We have walked into facilities with technically complete plans that were cited because the inspection program described in Section XI was never set up.
When CDMS develops an SPCC plan, the inspection program (monthly and annual logs using STI format) is set up at the same time and tracked on the compliance calendar. The 5-year technical review is scheduled. Training records are organized. The plan becomes a working document rather than a binder gathering dust until the next CUPA inspection.
For an explanation of which plan type applies to your facility, see our SPCC plan template guide: Tier I, Tier II, and PE-certified. For guidance on when an existing plan needs to be amended or renewed, see when and how to update your SPCC plan.
